NCS000249_Durham SWMP Update_20190422

City of Durham
STORMWATER MANAGEMENT PLAN
Permit Number NCS000249

Revision as of January 2019

Prepared by City of Durham, Public Works Department
Stormwater and GIS Services Division

Certification
I 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.

_________________
Marvin G. Williams
Director of Public Works

ix

Revision History
Permit Issue
Date

Stormwater Management Plan Revision Dates
10Oct2018 22Apr2019
23Apr2013 15Feb2014 15Jan2016 31Aug2017
4Jun2007 6May2010 29Nov2010 28Dec2011

x

Overview
This Stormwater Management Plan is the City of Durham’s program to comply with NPDES Phase
1 permit NCS000249. The permit includes the six minimum measures required of all Phase I and
Phase II programs in North Carolina as well as three additional measures required in Phase I
permits. For each of these nine management measures, the Stormwater Management Plan
defines the strategies and management practices the City is using for protecting water quality and
reducing pollutant discharges to the maximum extent practicable.
Since issuance of the first permit in 1994, the City of Durham’s stormwater program has
undergone considerable evolution. Each year, this program continues to evolve. The permit
requires the City to monitor and assess the effectiveness of the strategies and management
practices in its plan and to revise them as appropriate to improve program effectiveness. The city
monitors metrics related to workload, efficiency and effectiveness as well as outcomes such as
ambient water quality in urban streams and pollutant loads. City staff members also coordinate
with other cities in North Carolina to learn from their experience and successes. Because the City
of Durham’s challenges include nutrients, staff members have endeavored to learn from efforts
to control nutrient that are underway in the Chesapeake Bay. In addition, the City implements
studies and pilot programs to assess impacts and control measures as additional ways of
improving effectiveness.
Sections 1 through 6 of this Stormwater Management Plan (SMP) provide context, including
information on population, land use, the municipal stormwater system, receiving streams, and
existing water quality programs. SMP Section 7 contains the strategies and management
practices used to address the nine management measures and the three additional measures in
the NCS000249. SMP Section 7 is reviewed and updated at least annually. Other sections of the
Plan are periodically updated to reflect major changes.
Significant changes in the 2018 SMP
Changes resulting from permit application:
The application process required each permittee to discuss water quality limited streams, the
likely sources and causes of impairment, and the measures being undertaken to address water
quality limitation. A summary of this analysis and discussion is now included in the Stormwater
Management Plan in Section 2 Receiving Waters, supplementing the discussion of Total
Maximum Daily Loads (TMDLs) and nutrient strategies. Supporting analysis and further
discussion of impaired waters has been added to Appendix I - Target Pollutants, Sources &
Audiences.
Changes resulting from revisions in the permit:
A revised NCS000249 was issued effective October 10, 2018. Notable changes were made in the
annual reporting due date, post-construction measure and TMDL measure.
Annual reporting due date - In prior permits the reporting period has been October 1 through
September 30 with an annual report due date of January 15. The 2018 permit assumes fiscal
year reporting July 1 to June 30 and specifies an annual report due date of October 31. Because
the permit changes the reporting period and due date, and was issued only 21 days before
October 31, the City has obtained written approval from NCDEMLR using the prior schedule and
due date for the first annual report, and submitting the second annual report for the October 1 –
June 30 period as a means of transitioning to the new permit.
Post-construction Measure – The reissued permit appears to resolve a conflict between NC
Session Law 2017-10 and the permit and Stormwater Management Plan. As a result of the
revised permit and changes in the effective dates of the Jordan Lake rules, post-construction
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requirements within the Jordan Lake are based only on Phase II post-construction requirements,
and do not also include supplemental nutrient loading limits required under the Jordan Lake
rules.
TMDL Response Measure – In prior annual reports, the City of Durham has included reporting on
the City’s efforts to tailor and implement permit measures to address pollutants of concern and
their sources within two watersheds that assign waste load allocations to the City of Durham. The
reissued permit provides greater specificity regarding development and implementation of TMDL
response plans. The City has elected to initiate a review of existing TMDL Water Quality Recovery
Plans, and will be reporting on outcomes in future annual reports.
Other significant changes to the Stormwater Management Plan
SMP Section 7.5 construction site stormwater control has been expanded. The Sedimentation
and Erosion Control ordinance requirements in the City-County Unified Development Ordinance
have been revised, following review by NCDEMLR and approval by the Sedimentation Control
Commission. A brief discussion of the changes is provided at the beginning of Appendix D, which
includes the current ordinance provisions.
The Inventory of Municipal Facilities in Appendix J has been updated to include two new facilities.
Fire Station 17, a LEED certified facility co-shared by Durham County EMS and City of Durham Fire
Department, was placed in service August, 2018. The Transportation Department’s Sign and
Signal Shop moved to a new location after completion of renovation of the building at the new
site.

xii

Contents
1 Storm Sewer System Information .............................................................................................. 1-3
1.1 Population Served ............................................................................................................... 1-3
1.2 Growth Rate ........................................................................................................................ 1-3
1.3 Jurisdictional and MS4 Service Areas ............................................................................... 1-4
1.4 Stormwater Conveyance System (Public and Private) ...................................................... 1-7
1.5 Land Use Composition Estimates .................................................................................... 1-10
1.6 Land Use Estimate Methodology ..................................................................................... 1-10
2 Receiving Streams .................................................................................................................... 2-13
2.1 Hydrologic Units ................................................................................................................ 2-13
2.2 Receiving Streams with Index Numbers, 305(b) Status ................................................ 2-14
2.3 TMDL Identification ........................................................................................................... 2-20
2.4 Water Quality Limited Segments ..................................................................................... 2-22
3 Existing Water Quality Programs .............................................................................................. 3-41
3.1 Local Programs ................................................................................................................. 3-41
3.2 State Programs ................................................................................................................. 3-60
4 Permitting Information .............................................................................................................. 4-62
4.1 Responsible Party Contact List ........................................................................................ 4-62
4.2 Organizational Chart ......................................................................................................... 4-62
4.3 Signing Official .................................................................................................................. 4-63
4.4 Duly Authorized Representative ....................................................................................... 4-63
5 Co-Permitting Information (if applicable) ................................................................................ 5-64
5.1 Co-Permittees .................................................................................................................... 5-64
5.2 Legal Agreements ............................................................................................................. 5-64
5.3 Responsible Parties .......................................................................................................... 5-64
6 Reliance on Other government Entity(ies) ............................................................................... 6-65
6.1 Name of Entity ................................................................................................................... 6-65
6.2 Measure Implemented ..................................................................................................... 6-65
6.3 Contact Information .......................................................................................................... 6-66
6.4 Legal Agreements ............................................................................................................. 6-66
6.5 Recognition of Contributions ............................................................................................ 6-66
7 Stormwater Management Program (SMP) Plan ...................................................................... 7-68
7.1 Program Implementation ................................................................................................. 7-70
7.2 Public Education and Outreach on Stormwater Impacts ............................................... 7-79
7.3 Public Involvement and Participation .............................................................................. 7-84
7.4 Illicit Discharge Detection and Elimination ..................................................................... 7-87
7.5 Construction Site Stormwater Runoff Control ................................................................. 7-92
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7.6 Pollution Prevention and Good Housekeeping for Municipal Operations ................... 7-110
7.7 Pollution Prevention and Good Housekeeping for Municipal Operations ................... 7-120
7.8 Program to Monitor and Control Pollutants to Municipal Systems .............................. 7-130
7.9 Water Quality Assessment and Monitoring ................................................................... 7-136
7.10 Total Maximum Daily Loads (TMDLs) ............................................................................ 7-145
7.11 References ...................................................................................................................... 7-151

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List of Tables
Table 1-1. Population and Growth Rate for the City of Durham
Table 1-2. Population, Land Area and Density for the City of Durham
Table 1-3. Jurisdictional Area for the City of Durham (2017)
Table 1-4. Conveyance System Features for the City of Durham (Corrected and updated to March
2019)
Table 1-5. Percentage of Land Uses in the City of Durham
Table 1-6. Acronyms Associated with Figure 1.2 Map Legend
Table 2-1. City of Durham Watersheds
Table 2-2. Water Quality Classification and Receiving Stream Status for Indexed Streams by River
Basin
Table 2-3. EPA Approved TMDLs with Loads Assigned to the City of Durham
Table 2-4. Nutrient Sensitive Waters Subject to State Rule Making
Table 2-5. Watershed Planning Summary
Table 2-6. Industrial Facilities in Northeast Creek and Third Fork Creek
Table 2-7. Street Sweeping in the City of Durham, by Year
Table 3-1. Traditional monitoring programs
Table 3-2. Sediment and Erosion Ordinance Application
Table 7-1. BMP Summary Table for Public Education and Outreach
Table 7-2. BMP Summary Table for Public Involvement and Participation
Table 7-3. BMP Summary Table for the IDDE Program
Table 7-4. BMP Summary Table for the Post-Construction Stormwater Management Program
Table 7-5. Thresholds for Application of Stormwater Pollutant Requirements
Table 7-6. Nitrogen and Phosphorus Post-development Loading Limits
Table 7-7. BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations
Table 7-8. Municipal facility inspection priority categories, with risk of stormwater pollution,
inspection frequency, and current number of facilities in category.
Table 7-9. Overall Results of Staff Testing
Table 7-10. BMP Summary Table for Monitoring and Control of Pollutants Entering the MS4
Table 7-11. Inventory of Industrial and Light Industrial Facilities as of October 2018.
Table 7-12. Description of facility inspection priority levels, with 2018 category totals
Table 7-13. BMP Summary Table for Monitoring and Control of Pollutants Entering the MS4
Table 7-14. City of Durham Monitoring Goals and Programs
Table 7-15. Rotating Monitoring Schedule
Table 7-16. BMP Summary Table for EPA Approved TMDL Wasteload Allocations
Table 7-17. Water Quality Recovery Program Requirements (NCDENR 2007)

List of Figures
Figure 1-1. City of Durham Watersheds and Jurisdictional Boundaries
Figure 1-2. Land Use Composition within City of Durham Corporate Limits
Figure 3-1. Durham Sewage Discharges, 2007-2011.
Figure 3-2. Water Supply Watershed Overlay for the City of Durham
Figure 7-1. The Iterative Process of Stormwater Management
Figure 7-2. Classification of Outcome Levels
Figure 7-3. City of Durham Departmental Organization Chart
Figure 7-4. Public Works Department Organization (as of 10/29/2018)
Figure 7-5. City of Durham Post-construction Stormwater Treatment
Figure 7-6. Inspections priority flowchart showing the inspection frequency and
promotion/demotion of facilities based on routine inspection results.
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Acronyms used in the SMP
BIMS Basinwide Information Management System
BMP Best Management Practice (see SCM)
CWEP: Clean Water Education Partnership
DO Dissolved Oxygen
EAB Environmental Affairs Board
EEUDO Environmental Enhancements to the UDO
ETJ Extra Territorial Jurisdiction
EPA Environmental Protection Agency
FY Fiscal Year
GIS Geographic Information System
HAZMAT HAZardous MATerials
HOA Homeowners Association
IDDE Illicit Discharge Detection and Elimination
MOU Memorandum of Understanding
MS4 Municipal Separate Storm Sewer System
NC North Carolina
NCAC North Carolina Administrative Code
NCBI North Carolina Biotic Index
NCDEMLR North Carolina Division of Energy, Mineral and Land Resources
NCDEQ North Carolina Department of Environmental Quality
NCDOT North Carolina Department of Transportation
NCDWM North Carolina Division of Waste Management
NCDWR North Carolina Division of Water Resources
NOR Notice of Requirement
NOV Notice of Violation
NRCS Natural Resources Conservation Service
NPDES National Pollutant Discharge Elimination System
NSW Nutrient Sensitive Waters
PAH Polycyclic Aromatic Hydrocarbon
QAPP Quality Assurance Project Plan
SARA Superfund Amendments and Reauthorization Act of 1986
SCM Stormwater Control Measure (BMP)
xvi

Acronyms Used in the SMP, cont.
SOS State of Our Streams
SSO Sanitary Sewer Overflow
SMP Stormwater Management Program
SPPP Stormwater Pollution Prevention Plan
TMDL Total Maximum Daily Load
TP Total Phosphorus
TRI Toxic Release Inventory, Section 313 of Title III of SARA
TSS Total Suspended Solids
UDO Unified Development Ordinance, Durham City-County Planning
USGS U.S. Geological Survey
WLA Waste Load Allocation
WQI Water Quality Index (City of Durham)
WQRP Water Quality Recovery Program
WRF Water Reclamation Facility

1-1

Background
The City of Durham is authorized to discharge stormwater from the City’s Municipal Separate Storm
Sewer System (MS4) to receiving waters of the State in accordance with the discharge limitations,
monitoring requirements, and other conditions set forth in National Pollutant Discharge Elimination
System (NPDES) permit NCS000249 under Section 402(p) of the federal Clean Water Act. The City’s
municipal separate storm sewer system is located within the City of Durham jurisdictional area. The
system discharges to receiving waters within the Cape Fear River and Neuse River basins.
The City of Durham Municipal Separate Storm Sewer System is the system of drainage conveyances
owned and operated by the City of Durham. Durham’s MS4 is primarily the drainage conveyances in
City-owned streets and on City property. The City’s MS4 includes curbs, street gutters, catch basins,
storm drain pipes, swales, ditches, and other man-made conveyances designed or used for collecting
and conveying stormwater.
Permit History - On May 17, 1993 the City of Durham submitted its application for a NPDES
Municipal Stormwater Permit under the federal Clean Water Act’s Phase I regulations for medium
size cities. The City’s first permit was issued by the North Carolina Department of Environment and
Natural Resources with an effective date of December 30, 1994. Because the City made timely
application for permit renewal, this initial permit remanded in effect until a new permit became
effective, July 1, 2007.
On February 22, 2013, the City received its third permit, effective March 1, 2013. After the City
requested minor changes to 24-hour reporting requirements of discharges, the North Carolina
Department of Environment and Natural Resources agreed to the minor changes, and provided the
permit with the minor modifications. On October 10, 2018, the City received its fourth permit.
Permit Organization
Part I of the permit contains over-arching requirements as well as detailing permit coverage. Section
I.I requires the City to develop and implement a Stormwater Management Program (SMP) applicable
within the City’s jurisdictional area. The purpose of this plan is to establish the means by which the
City will achieve compliance with the permit (NCS000249) and the specific requirements of section
402(p) (3) (B) of the Clean Water Act. This section of the Clean Water Act requires that the City, to
the maximum extent practical and allowable under State or local law, effectively prohibit non-
stormwater discharges to the City's MS4 and that controls and management measures are
implemented by the City to reduce the discharge of pollutants from the MS4.
Part II of the permit requires the City to assess progress in implementation, effectiveness, and
results of the SMP and individual components of the program. As part of this assessment, the City is
required to provide information concerning areas of water quality improvement or degradation.
Municipal stormwater management is intended to be implemented in an iterative manner with each
five-year permit containing better tailored requirements, and municipal permittees responding with
better tailored, more advanced stormwater management programs. Iterative improvements may
also occur on a shorter cycle, with permittees making minor revisions to their management plans
annually.
After receipt of the 2007 permit, the City developed the initial version of this SMP with input from
City residents and other stakeholders. The initial SMP was submitted to the North Carolina Division
of Water Quality with the City’s first annual report under this permit term. The SMP has been
updated annually to include revised ordinances, to reflect changes in process, to reference written
operating procedures as they are revised, and to refine control measures or management practices
based on experience and assessment. Summary tables of inventories and demographics and
explanatory maps are generally updated every two to three years, with some updates occurring each
1-2

year to spread the workload. Current jurisdictional limits are available online using GoMaps via the
City’s website.
Permittees have been advised that NCDEQ will thoroughly review the SMP, annual reports, and
records on SMP implementation when the state audits the City’s municipal stormwater program.
Stormwater Management Program plans become enforceable parts of the permit under conditions
outlined in part II, section I.2 of the permit. Implementation of best management practices
consistent with the provisions of this plan will constitute compliance with the standard of reducing
pollutants to the maximum extent practicable.

1-3

1 Storm Sewer System Information
Intro sentence
1.1 Population Served
This Stormwater Program Management Program (SMP) addresses the City’s MS4 located within the
City of Durham municipal boundaries. The City of Durham is the fourth largest City in North Carolina
according to the 2000 census. Table 1-1 provides the population and estimated average annual
growth rate for the City of Durham and for Durham County as a whole.
Table 1-1: Population and Growth Rate for the City of Durham1
City-County
July 2017
Population
Estimate
2010
Population
2000
Population
Est. Annual
Percent Change
City of Durham 267,743 228,330 187,035 2.2%
Durham County 311,640 267,587 223,314 -

Durham has a rich history and a long heritage as a multicultural center.
Housing is roughly evenly split between owner-occupied and rental housing.
1.2 Growth Rate
The population growth rate for the City of Durham for 2000 to 2010 was 2.2% as shown in Table 1-1,
while for 2010 to 2017 it was 2.4%. Growth rates were calculated using the percent change
between population totals, annualized by dividing this percent change by the number of years.
Table 1-2 provides the population, land area, and population density for the City of Durham.
Population density remained relatively constant between 1990 and 2000 during which the City grew
through voluntary annexation. The increase in population density beginning in 2010 and increasing
in 2017 occurred in conjunction with redevelopment of the downtown area.
Voluntary annexation agreements are executed throughout the year, but formal annexations may be
deferred. The Planning Department updates jurisdictional boundaries after annexations formally
occur.

1 The source of this population data is the 1990 and 2000 Decennial Census information and population
estimates obtained from the following website: http://linc.state.nc.us/; 2017 estimates are from
www.census.gov.

1-4

Table 1-2: Population, Land Area and Density for the City of Durham 2,3
Parameter 1990 2000 2010 2017
Population 136,612 187,035 228,330 267,743
Land Area (sq. mile) 70.22 94.64 107.5 112.5
Density (pop/ sq. mile) 1,946 1,976 2,124 2,380

1.3 Jurisdictional and MS4 Service Areas
The City of Durham is the only incorporated municipality in Durham County. The City and County
enjoy a unique relationship, and jointly operate combined City-County Planning and City-County
Inspections Departments. The location of the City in relation to Durham County and major watershed
areas is provided in Figure 1-1.
The jurisdictional area with the City of Durham is provided below in Table 1-3.

Table 1-3: Jurisdictional Area for the City of Durham (2017)3
Incorporated Area Total Jurisdiction
110.3 square miles 110.3 square miles

By agreement with Durham County, the City of Durham does not exert authority over an Extra-
Territorial Jurisdiction or ETJ. The City’s authorities are constrained by its municipal boundaries.

2 1990, 2000, 2010 data was obtained from the same state website, http://linc.state.nc.us/, and represents corrected census data. 2010 land area
obtained from GIS layer of City jurisdictional extent.
3 2017 population estimate is from www.census.org, land area is from 2018 GIS layer of City jurisdictional area.
1-5

Figure 1-1: City of Durham Watersheds and Jurisdictional Boundaries 4

44 City boundaries in Figure 1-1 are based on GIS feature class gis_data.A1.Dur_City (updated March, 2017, contained in the
Administrative Boundaries dataset) maintained by Durham City-County Planning Department. Watershed boundaries are based
1-6

MS4 Service Area - A Municipal Separate Storm Sewer System or MS4 is a publicly-owned and
operated stormwater conveyance or system of conveyances. These conveyances can include curbs,
street gutters, catch basins, storm drain pipes, swales, ditches, and other man-made conveyances
designed or used for collecting and carrying stormwater. Any public entity that owns and operates a
stormwater conveyance system has an MS4, but not all MS4s are currently subject to regulation. An
MS4s’ service area is that land area that drains to the MS4.
The City of Durham owns and operates the system of drainage conveyances in City-owned streets
and on City property. The City’s MS4 includes curbs, street gutters, catch basins, storm drain pipes,
swales, ditches, and other man-made conveyances designed or used for collecting and conveying
stormwater.
There are other public entities that have MS4s in Durham, the largest of which is the system of
drainage conveyances within the rights-of-way of state and interstate highways operated by the NC
Department of Transportation (DOT).
Drainage conveyance on private property is not part of Durham’s MS4. Drainage easements on
private property are platted as private easements for the benefit of adjacent property owners,
allowing neighbors to alleviate blockages in the event the property owner does not do so. As
discussed below, most of the open channel drainage system and much of the stormwater piping in
Durham is privately-owned drainage– meaning the property owner is responsible for maintenance.
Private and public drainage systems are often interconnected. Drainage from some the City’s MS4
may enter a private system in some cases, and drainage from some private systems may enter the
City’s MS4.
As indicated in Section 1.4 below and discussed in Section 7.4, the City has developed a detailed
feature inventory and map of both the public and private system of drainage conveyance. Using the
inventory and map in combination with a parcel map, the City has determined MS4 features (this is
discussed further in the section below).
Typically a given piping system collects stormwater from multiple inlets and discharges through a
single outlet. 40% of inlets are owned by the City, while only 20% of outlets are owned by the City.
In order to estimate the City’s MS4 service area, some simplifying assumptions are needed. If it is
assumed that all surface drainage enters an inlet to a stormwater pipe, either public or private, and
that each inlet serves about the same drainage area, then the 2013 City of Durham MS4 service
area is estimated to be 40% of 108 square miles or 44 square miles. This is a conservative (over-)
estimate because some land drains directly to waters of the state from city parcels, most of which
are privately owned.
Determining the City of Durham MS4 Service Area with greater accuracy than this estimate will
require determining the drainage area of the inlets to the City’s MS4. This will require using surface
topography to delineate areas or “catchments” that drain to each inlet. If it becomes necessary, the
City will work toward developing a detailed map of non-city MS4s located within City limits (NC
Department of Transportation, Durham Technical Community College, North Carolina Central
University, Durham City-County School System, Durham County, etc.)
While the City recognizes that it does not have authority to enter private property for purposes of
operating, maintaining or retrofitting privately owned and operated stormwater systems, the City has
generally taken a comprehensive approach to stormwater management to the extent allowed by law.

streams and topographic data from high resolution aerial photogrametry mapping by Landmark under contract to City of Durham
Engineering. Watershed delineations have been modified to reflect the mapped stormwater piping network in addition to detailed
surface topography.
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For example, the City has mapped virtually the entire drainage system, including almost all public
and private system components 12 inches and larger. Similarly, the City’s illicit discharge ordinance
addresses non-stormwater discharges to both public and private components of the drainage
system, and the City has developed procedures for conducting investigation on private property that
recognize property rights, rules of evidence and due process.
1.4 Stormwater Conveyance System (Public and Private)
The existing City of Durham conveyance system is composed of curbs, gutters, catch basins, street
culverts, pipes, ditches and swales all located within the right-of-way of City streets and on City-
owned property. Much of the drainage in the City is on private property and is maintained by the
property owner; drainage easements on private property are platted as private easements.
The City has detailed (2-foot contour) topography and hydrology maps. The City also has mapped
stormwater inlets, underground pipes, manholes, junction boxes, street culverts, and other features
of the conveyance system that collect and convey storm water within the City of Durham. Mapping of
pipes initially focused on collecting data on pipes that are 12 inches and larger. Information on
smaller pipes is now collected as the maps are updated. Current minimum pipe size for new
construction is 15 inches. These maps include features on both public and private property.
As shown in Table 1-4 below, there are more than 676 miles of open channel sections in the City of
Durham. Of these channel miles, approximately 438 miles are identified as rivers and streams; 178
miles are identified as ditch. These drainage features have been identified based on detailed aerial
photogrametry used to develop Durham’s two-foot topographic mapping. These maps are used in
conjunction with US Geological Survey (USGS) and the Natural Resources Conservation Service
(NRCS) soil survey maps to determine where riparian zones should be protected from development.
Field determinations are used when necessary to determine the beginning of intermittent and
perennial stream segments.

1-8

Table 1-4: Conveyance System Features for the City of Durham (Corrected and updated to March
2019).
Linear conveyance features
Conveyance Feature
Total,
City-wide
2019
Storm drain pipe miles 972
Total storm drain pipe miles 972
Open Channel:
River miles 108
Stream miles 340
Ditch miles 179
Unknown miles 1a
Total open channel miles 628b
Number of pipe segments:
Storm drain pipe 61,469
Culvert 1816
Driveway 1813
Minor 502
Stub 1121
Unknown 3c
Total # of pipe segments 66,847

Point conveyance features (i.e. inlets, outlets) 2019
Conveyance Feature
Total,
City-
wide
Private City-
MS4 NCDOT
Durham
Schools
or County
NC
Drop inlets 14,532 10,467 1,534 1,825 472 234
Curb inlets 11,691 3,877 7,253 394 154 13
Combo inlets 22,555 8,788 10,080 3,386 217 84
Slab inlets 1,016 742 131 104 28 11
End-section or
Headwall inlets
6,909 3,128 2,255 1,446 30 50
Inlet Subtotal 56,703 27,002 21,253 7,155 901 392
Junction Boxes 1,091 722 172 169 15 13
Manholes 3,913 2,323 924 522 94 50
Connector Subtotal 5,004 3,045 1,096 691 109 63
End-section or
Headwall outlets**
11,299 7,252 2,317 1,562 100 68
Outlet Subtotal 11,299 7,252 2,317 1,562 100 68
Filterra 29 9 20
Manhole (BMP Access) 50 38 2 6 2 2
1-9

Riser Pipe 570 547 15 1 6 1
Weir 103 87 10 5 1
SCM-associated
Structures Subtotal
752 681 47 7 13 4
Other 441 369 30 25 17 0
Total, all nodes 74,199# 38,349 24,743 9,440 1,140 527

There are more than 56,703 stormwater inlets, 972 miles of stormwater pipe, and 11,299 outlets in
the City. Much of the conveyance system is private. Approximately 40% of the inlets and 20% of the
outlets are identified as City-owned and operated.
Often an outlet on private property may be discharging water collected from City inlets. The City’s
policy on conducting work on private drainage systems considers whether the private system
conveys street drainage.
There is an average of five inlets for each outlet. While there are approximately 11,299 outlets, many
of these involve small drainage areas and small pipes. Conveyance system features are summarized
in Table 1-4 above.
Major outfalls are generally those 36 inches or greater draining approximately 50 acres, except in
industrial areas where major outfalls include pipes 12-inches and greater, and drainages areas of
roughly two acres. 40CFR122.26 required initial field screening for illicit discharges at either major
outfalls, or at field screening points selected based on a grid analysis, with medium sized MS4s
required to identify 250 screening points, and large cities, 500 points. Before the City had mapped
the stormwater infrastructure, the City and its consultant (Ogden) used coarse USGS topographic
maps to identify 890 major outfalls draining an average 60 acres each, which grew to more than
1,100 major outfalls with subsequent annexations.
With availability of detailed mapping of stormwater infrastructure together with more detailed
topographic maps, in 2014 Stormwater & GIS Service staff produced a map of proposed major
outfalls to better guide illicit discharge screening, and they developed a database utility to update
the outfalls based on field conditions. Using drainage area to select outlets that drain 50 or more
acres, and eliminating pipe culverts, resulted in about 1,200 outfalls targeted for dry weather
screening.
The City’s stormwater system inventory is housed in an enterprise GIS database (ArcGIS) and has
been made available to the public on the City's online mapping web site. Development projects are
required to submit As-Built information in digital form that is used to update the inventory. Staff
members conduct field survey work to resolve conflicting information and to collect missing
information using a survey grade GPS.
There are more than 900 structural stormwater control measure (SCMs, also referred to as
structural best management practices or BMPs) within the City. Nearly all of these SCMs were
constructed during land development to manage peak flow and/or reduce pollutant concentrations.
Nearly all of the SCMs in the City are located on private property.
Current design standards require conveyances be designed for 25-year storm events for drainage
areas of 100 acres or more; smaller drainage area conveyances must be designed for ten-year storm
events. For open channel sections, flow must be non-erosive and contained within the channel.
Pipe systems must be designed to provide free-surface gravity flow throughout the system. Outlet
energy is commonly dissipated through the use of concrete headwalls, end-walls, or flared end
sections with riprap aprons. In newer development energy dissipation of this type tends to be limited
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to outlets discharging to wet ponds, swales, and other stormwater treatment practices. In many
cases the design is required to dissipate flows up to the one inch storm though level spreaders that
return the concentrated flow to a sheet flow discharged through a vegetated riparian buffer.
Maintenance and improvements to the MS4 system are funded by storm water utility fees collected
within the City of Durham. Under specific, limited circumstances, the City also implements drainage
projects on private property with the property owner’s permission and financial participation.
Ongoing maintenance of these projects remains the responsibility of the property owner.
The City provides comprehensive inspection and maintenance of the MS4 system through several
different programs. These include:
 Routine maintenance such as street sweeping that cleans debris from inlet grates;
 Routine cleaning of catch basin sumps, during which pipes are inspected and cleaned as necessary;
 Routine inspection of major public and private stormwater outfalls that identifies illicit discharges,
structural issues and maintenance needs so that they can be dealt with appropriately; and
 Removal of debris and blockages from channels where such materials could cause or contribute to
flooding.
Improvements to the drainage system include stream restoration projects using natural channel
design techniques, channel stabilization, small scale drainage improvement projects that address
localized flooding, master planning for water quality improvements and habitat enhancement, and
retrofitting to provide stormwater treatment.
1.5 Land Use Composition Estimates
The number of square miles and percentage of the MS4 service area under residential, commercial,
industrial, and open space land use categories are provided in Table 1-5. This data is for land within
the corporate limits of the City of Durham.

Table 1-5: Percentage of Land Uses in the City of Durham

Land Use Category % of Land Use within
City
Residential 30%
Commercial, Office, Institutional 19%
Industrial 4%
Open Space 20%
Agriculture 7%
Right of Way 19%

1.6 Land Use Estimate Methodology
The land use data in Table 1-5 was derived from Durham County 2018 existing land use, and right-
of-way datasets, and updated using the 2018 land parcel dataset. Figure 1-2 provides an updated
map of the land use within the 2018 City of Durham corporate limits.

Table 1-6: Acronyms Associated with Figure 1.2 Map Legend
1-11

Abbreviation Land Use Category
ROS Recreation/Open Space
VAC Vacant
UTL Utilities
IND Industrial
COM Commercial
OFC Office
PUB Public or Institutional
HDR High Density Residential
LDR Low Density Residential
MDR Medium Density Residential
VLR Very Low Density Residential
AGR Agricultural

1-12

Figure 1-2: Land Use Composition within City of Durham Corporate Limits 5

5 City land use in Figure 1-2 based on March, 2019 municipal boundaries and GIS feature class gis_data.A1.ELU contained in the Planning
dataset, maintained by Durham City-County Planning Department. See Table 1-6 on the next page for a list of acronyms associated with the map
legends existing land use.
2-13

2 Receiving Streams
The high point within the City of Durham is a ridgeline that roughly divides the City into two major
river basins: the Cape Fear River Basin and the Neuse River Basin. The City is almost evenly split;
51.8% of the City drains to the Neuse River Basin and 48.2% to the Cape Fear River Basin.
As a rough guide, waters to the south and west of the Durham Freeway (Highway 147) are generally
in the Cape Fear River Basin. This part of the City drains first to B. Everett Jordan Lake (i.e., Jordan
Lake), the Cape Fear River, and finally the Cape Fear Estuary near Wilmington, NC.
Waters north and east of the Durham Freeway are generally in the Neuse River Basin. These waters
flow first to Falls Lake, the Neuse River and finally the Albemarle-Pamlico Sound. The exception is
Stirrup Iron Creek in southeast Durham County which does not drain into Falls Lake, but drains into
Crabtree Creek and enters the Neuse River downstream of Falls Lake.
Since the City sits along a high point, many streams originate within the City. Waters that do not
begin within the City are the Eno River and New Hope Creek, both of which originate in Orange
County to the west of Durham. In all streams, human development and activity control the hydrology
and water quality. For example, the natural alignment of many receiving streams has been altered
over the past century. In the early 1960s, the US Army Corps of Engineers straightened and dredged
Ellerbe Creek to form a trapezoidal channel to alleviate flooding. The Corps continues to require
removal of large woody vegetation as maintenance of this flood control project. A section of Goose
Creek was similarly channelized and lined with concrete in the 1970s.
In areas where there were no US Army Corps of Engineers flood control projects, there are still
localized drainage problems. The City maintains a flood warning system for areas along the Eno River
in the Old Farm and River Forest neighborhoods. Additionally, the City completed hazard mitigation
grant program buyouts in the Old Farm/River Forest area along the Eno River and along a tributary of
Ellerbe Creek. There are currently seven properties with hazard mitigation grant programs, and nine
additional applications have been submitted related to Hurricane Florence. More recently the City
has devoted efforts to addressing localized flooding problems that impact or may impact occupied
dwellings. Floodplain maps were updated in 2018.
Another example of human development affecting hydrology and water quality is the lack of
vegetation along stream banks in some areas of Durham. Development regulations first began
protecting selected riparian buffers in 1994. Further regulations protected all riparian buffers in
2002.6 However, these regulations exempt existing uses. In many older developed areas, much of
the woody vegetation that helps to anchor stream banks against erosion has been removed. Many
stream banks remain vegetated in the newer developed areas. Efforts are underway to establish
woody riparian vegetation where feasible.
2.1 Hydrologic Units
The City of Durham has eleven hydrologic unit drainage areas, as listed in Table 2-1.

Table 2-1: City of Durham Watersheds
Cape Fear River Basin Watersheds Hydrologic Unit Code
New Hope Creek 303000206011, 303000206013
Little Creek 303000206010
Third Fork Creek 303000206012

6 Utility easement maintenance also impacts vegetation along waterways. The City is working with utilities to try to change some of the ways
these easements are maintained to allow riparian buffers to form.
2-14

Table 2-1: City of Durham Watersheds
Cape Fear River Basin Watersheds Hydrologic Unit Code
Crooked Creek 303000206013
Northeast Creek 303000206014
Neuse River Basin Watersheds
Eno River 302020103004
Ellerbe Creek 302020105001
Panther Creek 302020105001
Little Lick Creek 302020105002
Lick Creek 302020105003
Stirrup Iron Creek 302020108001

For convenience and recognizing natural boundaries, the City has further sub-divided some of these
watersheds. The Ellerbe Creek hydrologic unit has been divided into Ellerbe Creek proper and
Panther Creek. Similarly, New Hope Creek consists of three components: the main portion of New
Hope Creek and its two urban tributaries: Mud Creek and Sandy Creek. A map of these watersheds
and their hydrologic units and major subdivisions is provided in Figure 1-1.
2.2 Receiving Streams with Index Numbers, 305(b) Status
Stream segments listed on the NC Basinwide Information Management System (BIMS) website in
Durham County that currently receive runoff from the City of Durham (or that may do so as the City
grows) are provided in Table 2-2 at the end of this section. The table includes 38 segments in the
Neuse River Basin and 22 segments in the Cape Fear River Basin. The table includes larger streams
and the major tributaries of those streams; however, the BIMS system does not include small
tributaries.
The receiving stream tables below include the stream index number and the name used by NC
Division of Water Resources (DWR) (any known alternate names are listed in parenthesis). Stream
names are often not unique. North Carolina uses its own stream index numbering system in order to
avoid confusion in identifying streams. North Carolina designates the uses of a water body through
water quality classifications (this also determines which water quality standards are applicable to
that water body.)
Table 2-2 also includes water quality limited status information from the 2014 305(b) integrated
report for waters in Category 4 that exceed standards but that have an approved management
strategy, waters in Category 5 which exceed standards but have no Total Maximum Daily Load or
other management plan in place, and waters in Category 3 that have a TMDL or management plan in
place. Location and descriptive information in Table 2-2 has been supplemented based on
evaluation of the 2016 Integrated Report available on the DWR website
(https://deq.nc.gov/about/divisions/water-resources/planning/modeling-assessment/water-quality-
data-assessment/integrated-report-files).
All waters in the state are listed as Category 4t for fish tissue mercury. No separate listing or
discussion is provided below since the primary source is drift from upwind states.

2-15

Table 2-2: Water Quality Classification and Receiving Stream Status for BIMS Indexed Streams by River Basin in
Durham County
Neuse River Basin; Subbasin 03-04-01
# Receiving Stream
Name Description
Stream
Index
Number
City/MS4
Water Quality
Use
Classification
Water Quality Limited,
Parameter, IRCategory
(collection year,303d
year)

1
Falls Lake below
normal pool
elevation (NEUSE
RIVER)
Falls, Lake, From source
(confluence of Eno River
Arm of Falls Lake and Flat
River Arm of Falls Lake) to
I-85 bridge, 2,704 FW
acres
27-(1) Downstream
of City
WS-IV; NSW; CA

Chlorophyll a, 4b
(2012/2008) Turbidity, 5
(2012/2008)
2
Falls Lake below
normal pool
elevation (NEUSE
RIVER)
Falls, Lake, From I-85
bridge to Panther Creek,
877.8 FW acres
27-(5.5)a Downstream
of City
WS-IV; B; NSW;
CA

Chlorophyll a, 4b
(2012/2008) Turbidity, 5
(2012/2010)
3
Falls Lake below
normal pool
elevation (NEUSE
RIVER)
Falls, Lake, From Panther
Creek to Ledge Creek Arm,
3,316 FW acres
27-(5.5)b1 Downstream
of City
WS-IV; B; NSW;
CA

Chlorophyll a, 4b
(2012/2008)
4
Falls Lake below
normal pool
elevation (NEUSE
RIVER)
Falls, Lake, Ledge Creek
Arm, FW 1,236 acres 27-(5.5)b2 Downstream
of City
WS-IV; B; NSW;
CA

None
5 Eno River

From Orange County SR
1561 to U. S. Highway
501, 16.2 miles
27-2-(10)

Portion within
City
WS-IV; B; NSW
None
6 Sevenmile Creek
759-F07 From source to Eno River 27-2-15

Not in City,
but receives
runoff
WS-IV; NSW
Not assessed
7
Jumping Run
(a.k.a. Warren
Creek)
760-C10
From source to Eno River,
3.4 miles 27-2-17 City WS-IV; NSW None
8 Mill Creek (Crystal
Lake) 873-A01
From source to Jumping
Run 27-2-17-1 City WS-IV; NSW Not assessed
9
Crooked Creek
(a.k.a. Crooked
Run Creek) 760-
D08
From source to Eno River,
5.2 miles 27-2-18 Portion within
City WS-IV; NSW None
10 Eno River
From U. S. Highway 501 to
a point 0.5 mile upstream
of City of Durham
emergency pumping
facility raw water intake
(Lat: 36 04' 40 Long: 78
53' 00), 1,6 miles
27-2-(19)

Portion within
City
WS-IV; NSW
None
11 Eno River
From a point 0.5 mile
upstream of Durham
emergency pumping
facility raw water intake to
Durham emergency
pumping facility raw water
intake. (0.4 miles)
27-2-
(19.3)

Portion within
City
WS-IV; NSW, CA
None
2-16

Table 2-2: Water Quality Classification and Receiving Stream Status for BIMS Indexed Streams by River Basin in
Durham County
Neuse River Basin; Subbasin 03-04-01
# Receiving Stream
Name Description
Stream
Index
Number
City/MS4
Water Quality
Use
Classification
Water Quality Limited,
Parameter, IRCategory
(collection year,303d
year)

12 Eno River
From City of Durham
emergency pumping
facility raw water intake to
a point 0.5 mile upstream
of Little River, 4.3 miles
27-2-
(19.5)

Portion within
City
WS-IV; NSW
None
13 Cub Creek From source to Eno River 27-2-20 Portion within
City WS-IV; NSW Not assessed
14 Eno River
From a point 0.5 mile
upstream of Little River to
Falls Lake, Neuse River
27-2-
(20.5)

Not in City,
but is
downstream
WS-IV; NSW, CA
Not assessed
15 Little River (Little
River Reservoir)
From a point 0.1 mile
upstream of Durham Co
SR 1461 to dam at Little
River Reservoir (32.4 FW
acres)
27-2-21-
(3.5)
Portion of
watershed
within City
WS-Ii; HQW
NSW, C None
16 Little River
From dam at Little R
Reservoir to a point 0.9
miles from mouth, 6.5
miles
27-2-21-
(6)
Outside of
City WS-IV; NSW None
17 Cabin Branch From source to Little
River 27-2-21-7
Portion of
watershed
within City,
Brown WTP
WS-IV; NSW Not assessed
18 Ellerbe Creek
From source to I-85 bridge
(near Broad Street), 6.1
miles
27-5-(0.3) Entirely in
City
WS-V; NSW

Fish Community Poor, 5
(2005/1998)
19 Ellerbe Creek
From I-85 bridge (near
Club Blvd)to a point 0.2
miles upstream of Durham
Co SR 1636 (Glenn Road),
5.9 miles
27-5-(0.7) 4.2 miles in
City
WS-IV; NSW

Fish Community Poor, 5
(2005/1998))
20 Ellerbe Creek
From a point 0.2 miles
upstream of Durham Co
SR 1636 (Glenn Road) to
Falls Lake, Neuse River
(0.52 miles)
27-5-(2)
1.4 miles
downstream
of City
WS-IV; NSW; CA

Benthos fair, 5 (2008,2008)

21 South Ellerbe
Creek
From Source to Ellerbe
Creek Entirely in
City WS-V; NSW Not assessed
22 Goose Creek
From source to Ellerbe
Creek (note not all of
Goose Creek is WSWS)
27-5-1 Entirely in
City WS-IV; NSW Not assessed
23 Panther Creek
From source to a point 1.1
mile downstream of
Durham Co SR 1818
(Burton Road) (3.6 Miles)
27-6-(1) 1.6 miles
within City WS-IV; NSW Not assessed
24 Panther Creek
From a point 1.1 mile
downstream of Durham Co
SR 1818 (Burton Road) to
Falls Lake
27-6-(2) Portion within
City WS-IV; NSW; CA Not assessed
2-17

Table 2-2: Water Quality Classification and Receiving Stream Status for BIMS Indexed Streams by River Basin in
Durham County
Neuse River Basin; Subbasin 03-04-01
# Receiving Stream
Name Description
Stream
Index
Number
City/MS4
Water Quality
Use
Classification
Water Quality Limited,
Parameter, IRCategory
(collection year,303d
year)

25
Rocky Branch
(Petty Lake, S of
Redmill Rd)
From source to a point 0.5
mile upstream of Durham
Co SR 1802 (Creech
Road)
27-7-(1)
Currently
outside of
City
WS-IV; NSW Not assessed
26 Rocky Branch
From a point 0.5 mile
upstream of Durham Co
SR 1802 to Falls Lake
27-7-(2) Outside of
City WS-IV; NSW; CA Not assessed
27 Little Lick Creek
(Patterson Rd)
From source to a point 0.4
mile upstream of Durham
Co SR 1811 (Patterson
Road), 7.2 miles
27-9-(0.5) 2.7 miles
within City WS-IV; NSW
Dissolved oxygen, 5
(2007/2008)
Turbidity, 5 (2007/2008)
Benthos poor, 4s (2000/ - )
28
Little Lick Creek
(including portion
of Little Lick Creek
arm of Falls Lake)
From a point 0.4 mile
upstream of Durham Co
SR 1811 to Falls Lake,
Neuse River (0.6 miles)
27-9-(2)
1.9 miles
downstream
of City
WS-IV; NSW; CA

Dissolved oxygen, 5
(2007/2008)
Turbidity, 5 (2007/2008)
Benthos poor, 4s (2000/ - )
29 UT2 to Little Lick
Creek
From source to Little Lick
Creek (2.4 miles (2.4
miles)
27-9-
(0.5)ut2 City WS-IV; NSW; Dissolved oxygen, 5
(2007/2008)
30 UT2 to Little Lick
Creek
From source to Falls Lake
Little Lick Creek (0.9
miles)
27-9-
(2)ut2
Currently
outside of
City
WS-IV; NSW, CA Dissolved oxygen, 5
(2007/2008)
31 Chunky Pipe Creek From source to Little Lick
Creek 27-9-1 Outside city WS-IV; NSW Not assessed
32 Lick Creek
From source to Durham
Co SR 1809 (Southview
Road), 6.5 miles
27-11-
(0.5)
3.1 miles
within City WS-IV; NSW Benthos fair, 5 (2000,1998)
33 Lick Creek
From Durham Co SR 1809
(Southview Road) to Falls
Lake
(Rocky Branch tributary is
located outside City), 0.7
miles
27-11-
(1.5)
3.2 miles
downstream
of City
WS-IV; NSW; CA
Benthos fair, 5 (2000,2004)
34 Brier Creek
From source to Crabtree
Lake, Crabtree Creek (6.5
miles)
27-33-4
Outside City
(0.1 miles in
Durham
County)
C; NSW PCB Fish Tissue Advisory, 5
(2012/2008)
35 Little Brier Creek
From source to Brier
Creek
(5.3 miles)
27-33-4-1 1.0 miles in
City C; NSW PCB Fish Tissue Advisory, 5
(2012/2008)
36 Stirrup Iron Creek From source to Brier
Creek 27-33-4-2 Portion within
City C; NSW Not assessed
37
Page Branch
tributary to Stirrup
Iron Creek
From source to Stirrup
Iron Creek Not listed Portion within
City Not listed Not assessed
38
East Fork tributary
to Stirrup Iron
Creek
From source to Stirrup
Iron Creek Not listed Portion within
City Not listed Not assessed

2-18

Table 2-2: Water Quality Classification and Receiving Stream Status for BIMS Indexed Streams by River Basin in Durham County
Cape Fear River Basin; Subbasin 03-06-05
# Receiving Stream
Name
Description

Stream
Index
Number
City/MS4
Water Quality
Use
Classification
Water Quality Limited
Parameter,
IRCategory(collection
year,303d year)
39 New Hope Creek From source to a Sandy
Creek, 17.5 miles
16-41-1-
(0.5)a
Portion within
City WS-V; NSW None
40 New Hope Creek
From source to a point 0.3
mile upstream of Durham
Co SR 2220 (Old Chapel
Hill Road)
16-41-1-
(0.5)b
Portion within
City WS-V; NSW Not assessed
41 Mud Creek From source to New Hope
Creek 16-41-1-10 Portion within
City WS-V; NSW Not assessed
42 Sandy Creek From source to New Hope
Creek 16-41-1-11 Entirely in City WS-V; NSW Not assessed
43
New Hope Creek
From a point 0.3 mile
upstream of Durham Co SR
2220 o Durham Co SR
2220 (Old Chapel Hill Rd)
(0.4 miles)
16-41-1-
(11.5)a
0.4 miles
within City
WS-IV; NSW

Dissolved oxygen, 4c
(2012,1998)
Benthos Fair, 5 (1987/2006)
44
From Durham Co SR 2220
(Old Chapel Hill Rd) to I-40
(3.5 miles)
16-41-1-
(11.5)b
2.3 miles
within City WS-IV; NSW
Dissolved oxygen, 4c
(2012,2006)
Benthos Fair, 5 (1987/2000)
45
From I-40 to a point 0.8
mile downstream of
Durham Co SR 1107
(Stagecoach Road) (4.0
miles)
16-41-1-
(11.5)c
0.3 miles in
City WS-IV; NSW Benthos Fair, 4c
(1987/2000)
46
Third Fork Creek
From source to a point 2.0
miles upstream of N.C.
Hwy. 54, 5.2 miles
16-41-1-
12-(1) Entirely in City WS-V; NSW

Copper, 5e (2012/2012)
Dissolved oxygen, 5
(2012/2008)
Turbidity, 3t1/4t,( 2012/ - )
Zinc, 5 (2012/2008)
Benthos poor, 4s (1993/ - )
47
From a point 2.0 miles
upstream of N.C. Hwy. 54
to New Hope Creek, 3.9
miles
16-41-1-
12-(2) Entirely in City WS-IV; NSW

Copper, 5e (2008/2008,
Dissolved oxygen, 5
(2012/2008)
Benthos poor, 4s (1993/ - )
48 Gum Creek From source to New Hope
Creek 16-41-1-13 Portion in City WS-IV; NSW
Not assessed
2-19

Table 2-2: Water Quality Classification and Receiving Stream Status for BIMS Indexed Streams by River Basin in Durham County
Cape Fear River Basin; Subbasin 03-06-05
# Receiving Stream
Name
Description

Stream
Index
Number
City/MS4
Water Quality
Use
Classification
Water Quality Limited
Parameter,
IRCategory(collection
year,303d year)
49
New Hope Creek
(including New
Hope Creek Arm of
New Hope River
Arm of B. Everett
Jordan Lake)
From a point 0.8 mile
downstream of Durham Co
SR 1107 (Stagecoach
Road) to confluence with
Morgan Creek Arm of New
Hope River Arm of B.
Everett Jordan Lake, 1,416
acres
16-41-1-
(14)
Not in City,
but is
downstream
WS-IV; NSW; CA
Chlorophyll a, 4t (2012,
2002)
Turbidity,5 (2012,2006)
50 New Hope River
arm of Jordan Lake
From source at confluence
of Morgan Creek and New
Hope Creek arm of Jordan
Lake to Chatham Co,
1,200 FW acres
16-41-(0.5)
Not in City,
but is
downstream
WS-IV; B; NSW;
CA
Chlorophyll a, 4t (2012,
2002)
51
Little Creek
From source to a point 0.7
mile downstream of
Durham Co SR 1110
(Farrington Road), 4.9
miles
16-41-1-
15-(0.5)
1.4 miles in
City
WS-IV; NSW

Benthos poor, 5
(2001/2000)
52
From a point 0.7 mile
downstream of Durham Co
SR 1110 to New Hope
Creek
16-41-1-
15-(3)
1.1 miles
downstream
of City
WS-IV; NSW; CA Not assessed
53 Crooked Creek
(Southwest Creek)
From source to a point 0.7
mile upstream of mouth
(6.2 miles)
16-41-1-
16-(1)
3.4 miles in
City WS-IV; NSW Not assessed
54

Northeast Creek

From source to N.C. Hwy.
55
16-41-1-
17-(0.3) Portion in City WS-V; NSW Not assessed
55
From N.C. Hwy. 55 to
Durham Triangle WWTP,
3.3 miles
16-41-1-
17-(0.7)a
2.8 miles in
City WS-IV; NSW
Copper, 5 (2008/2008)
Dissolved oxygen, 4c
(2012/2008)
Fecal coliform, 4t (2012/-)
56
From Durham Triangle
WWTP to Kit Creek (3.3
miles)
16-41-1-
17-(0.7)b1
Downstream
of City
(Parkwood
Lake)
WS-IV; NSW Zinc, 3e/5 (2008/2008)
57
From Kit Creek to a point
0.5 mile downstream of
Panther Creek (3.2 miles)
16-41-1-
17-(0.7)b2
Not in City or
County WS-IV; NSW
Copper, 5e (2008/2008)
Fecal coliform, 4t (2012/-)
Zinc, 5 (2008/2008)
58
Burdens Creek
From source to Durham Co
SR 2028
16-41-1-
17-1-(0.3) Not in City WS-V; NSW Not assessed
59 From Durham Co SR 2028
to Northeast Creek
16-41-1-
17-1-(0.7) Portion in City WS-IV; NSW Not assessed
60 Buck Branch From source to Burdens
Creek
16-41-1-
17-1-1
Small portion
in City WS-IV; NSW Not assessed
2-20

Water Quality Classification
B Primary Recreation, Fresh Water
C Aquatic Life, Secondary Recreation, Fresh (all Class C would become WS-V under 15A NCAC
02B.0262)
CA Critical Area
HQW High Quality Waters
NSW Nutrient Sensitive Waters
ORW Outstanding Resource Waters
WS-II Water Supply II -- Undeveloped
WS-III Water Supply III -- Moderately Developed
WS-IV Water Supply IV -- Highly Developed
WS-V Water Supply V -- Upstream
For more information see: http://h2o.ehnr.state.nc.us/csu/swc.html

Integrated Report Categories for Water Quality Limited Segments
3e Metals exceeding standard more than once in last three year. Criteria is not used for category
5 assessments in NC.
3t1 Greater than 10% of sample results exceeded standard criteria, did not have 90% statistical
confidence of sample results, approved TMDL is in place for parameter
4t Exceeding Criteria but has an EPA approved TMDL for parameter
4c Exceeding Criteria due to the presence of a water control structure (e.g., dam).
4s Biological data is exceeding criteria, but there is another aquatic life parameter in category 4
or 5
5 Exceeding Criteria, there is no approved TMDL or management plan in place for parameter
5e Greater than 10% criteria exceeded, and did not have 90% statistical confidence of sample
results. EPA listed the AU based on EPA guidance

Methodology - Several sources were used to compile the information in Table 2-2.
 Initially water body names, stream index numbers and water quality classifications were obtained from
the NC Division of Water Quality BIMS web site for Durham County (10/18/07). This information has
since been updated using the most recent 305(b) Integrated Report, included subdivided segments.
 In the Jordan Lake watershed, all Class C waters were reclassified as WS-V under 15A NCAC
02B.0262, effective August 2009.
 In the Falls Lake watershed, all Class C waters were reclassified as WS-V under 15A NCAC 02B.0275,
effective January 2011.
 Water quality limited data (parameter and year) have been updated based on the 2014 305(b)
integrated Report and the 2014IR shapefile.
 The tables include a “City” column to designate water bodies that receive runoff from the City of
Durham. Heads-up evaluation of maps and GIS resources was used to assess whether a stream was
located in the City or received runoff from the City. In areas where the City may annex property, some
streams that currently do not receive runoff have been left on the list to facilitate correlation of stream
identification where the names used in the BIMS system are different than those used by the City.
2.3 TMDL Identification
Section 303(d) of the federal Clean Water Act requires North Carolina to:
2-21

 Identify and establish a priority ranking for water bodies that do not meet applicable water quality
standards (referred to as the 303(d) list);
 Establish Total Maximum Daily Loads or Management Plans for the pollutants causing impairment of
these water bodies; and
 Submit the list of Water Quality Limited waters and the TMDLs to the U.S. Environmental Protection
Agency (EPA) for approval.
A Total Maximum Daily Load (TMDL) is a pollution diet. For a water body that is not meeting a water
quality standard, a TMDL determines the pollutant/s primarily responsible for the water quality
violations and establishes the allowable pollutant loading (including a margin of safety) that will
result in the water body meeting water quality standards.
The North Carolina 303(d) list is normally updated every two years. Stormwater staff review the draft
list and may provide comments or corrections. The City’s monitoring program provides more detailed
information about conditions in the city’s receiving streams. Additional information on water quality
conditions, 303(d) listing and TMDLs may be found in NPDES MS4 Annual Reports in the TMDL
Response Plans (before 2014, Water Quality Recovery Plans).
The City prepares annual updates to the TMDL Implementation Plans for two watersheds, which are
subject to a TDML that assigns a Waste Load Allocation to the City of Durham. These plans include
detailed information on the watershed, the assigned Waste Load Allocation, implementation
measures, and progress being made.
Table 2-3 lists the Environmental Protection Agency approved TMDLs assigned to bodies of water
within the City of Durham. The City is also subject to regional TMDLs for nutrient impairment in the
Neuse Estuary near New Bern, NC and for nutrient impairment in Jordan Lake, as discussed further
below.
Table 2-3: EPA Approved TMDLs with Loads Assigned to the City of Durham
Water Body
Water
Quality
Violations
Target
Pollutant Status
Northeast
Creek
Fecal
coliform
bacteria
Fecal
coliform
bacteria
Approved,
Sept. 12,
2003
Third Fork
Creek Turbidity Sediment
Approved,
Jan 11,
2005

In addition to the 303(d) list and the TMDLs associated with it, the state also requires the
development of Management Plans for waters designated as Nutrient Sensitive Waters (NSW).
Portions of the City drain to the NSW waters shown in Table 1-8.
Table 2-4: Nutrient Sensitive Waters Subject to State Rule-Making
Water
Body
Location of
Impairment
Water
Quality
Violations
Target
Pollutant(s)
Percent
Reduction
Rule-
making
Status
Coverage
within the
City of
Durham
2-22

Neuse
River
Estuary
Estuarine
portion of
Neuse River
below New
Bern
dissolved
oxygen,
chlorophyll a
Total
Nitrogen TN: 30%
Adopted
as temp
rule 7/97,
perm rule
August
1998
8%
Upper
New Hope
Arm of
Jordan
Lake
Jordan Lake
above SR1008 chlorophyll a
Total
Nitrogen,
Total
Phosphorou
s
TN: 35%
TP: 5% (a) 48%
Upper
New Hope
Arm of
Jordan
Lake &
New Hope
Creek
From a point
0.8 mile
downstream of
Durham Co SR
1107 to
confluence
with Morgan
Creek Arm of
New Hope
River Arm of B.
Everett Jordan
Lake
turbidity
No separate target at
this time:
as sediment and
phosphorus runoff, and
in-situ algal growth are
reduced, the turbidity
standard in Jordan Lake
is expected to be met.
Addendu
m to
Jordan
Reservoir
TMDL,
April,
2014
48%
Falls Lake
below
normal
poll
elevation
Falls Lake
(turbidity:
above Panther
Creek)
chlorophyll
(a), turbidity
Total
Nitrogen,
Total
Phosphorou
s, Sediment
TN: 40%
TP: 77%
Rules
adopted
November
18, 2010
44%
(a) Session law 2016-94 states the Jordan Lake nutrient management strategy rules shall not take
effect and are subject to review and readoption. The EMC was instructed to begin rule readoption
by March 15, 2019. Subsequent legislation in SL 2018-5 instructed the EMC to begin readoption
upon receipt of a study and recommendations prepared by the NC Policy Collaboratory or
December 31, 2020. Although Jordan Lake appears in this table, nutrient management is not
currently required for Jordan Lake.
The City has been implementing a state-approved Neuse River NSW Stormwater Management
Program since 2001. In 2012 the City adopted revisions to post-construction performance
standards that comply with Jordan Lake and Falls Lake NSW rules. The City will revise its ordinances
and the stormwater management plan in 2019.

2.4 Water Quality Limited Segments
This section presents water quality limited stream segments, the likely sources and causes of the
impairment, and the existing programs that address the pollutant of concern if any. Water quality
limited waters are identified in Table 2-2 above. This table includes information from the 2016 North
Carolina 305(b) integrated report for waters in multiple categories, as follows:
• Category 3. Unable to Determine if stream segment is meeting or exceeding criteria
• Category 4. Exceeding criteria and a Total Maximum Daily Load (TMDL) is not required, and
2-23

• Category 5. Exceeding criteria and a TMDL is required (303(d) List).
A discussion of the sources and causes of the water quality limitations is provided in Appendix I.
Two City streams TMDLs are thoroughly addressed through TMDL Response Plan updates provided
with each of the annual reports submitted for the NCS0000249. Information from that work is
included below where it can inform understanding of issues in other streams that receive surface
runoff from the City of Durham.
Channel segments of the following streams (or tributaries thereof) are included in the discussion
below: Ellerbe Creek, Little Lick Creek, Lick Creek, Brier Creek, New Hope Creek, Third Fork Creek,
Little Creek, and Northeast Creek.
The discussion is organized by the parameter for which the segment is listed, and includes the
following: copper, zinc, polychlorinated biphenyls, dissolved oxygen, turbidity, fish community, and
benthic community. The City of Durham has been monitoring for benthic community since 2002 and
for metals since 2003.
2.4.1 Watershed Planning
Several of the pollutants of interest have been considered in watershed plans completed to date.
The City of Durham has completed watershed plans for the streams listed in Table 2-5 below.

Table 2-5 Watershed Planning Summary
Watershed
Area in
Durham Co.
(sq. mi.)
Area in
City
(sq. mi.)
Percent
Impervious
Stream Length Assessed
(stability rating)
Ellerbe Creek &
Panther Creek 36.0 19.3 32%
35 miles
(21% rated poor, 44%
fair)
Eno River 29.0 16.0 22% 49 miles
(5% rated poor, 53% fair)
Third Fork Creek 16.6 16.6 25.4%
13.5 miles
(19% rated poor, 35%
fair)
Northeast Creek &
Crooked Creek 56.1 14.6 17%
65 miles
(28% rated poor, 73%
fair)
Little Lick Creek 22.3 7.3 12%
26 miles
(52% rated poor, 43%
fair)

Each of these plans used similar approaches, including field work, desktop GIS analysis, and
watershed modeling. The field work for the development of each plan included assessing many miles
of stream channel. During this stream assessment field work, the channel was assessed for stability
and dimensions were collected for modeling. In addition, utility crossings and other features were
2-24

documented and any potential pollutant sources were noted for further investigation. Field work also
included assessment of existing SCMs, and assessment of potential retrofit locations.
Watershed plans also included a comprehensive review of water quality data, in some cases in
conjunction with the field work. A PCSWMM watershed model was developed for each plan, while a
variety of other watershed models may have been developed or updated depending upon the plan.
These models include WARMF, LSPC, or WIP Tools. The watershed models were calibrated to
existing data and were used to evaluate pollutant removal by BMPs in a combination of scenarios.
Watershed planning activities are mentioned below where relevant information was generated for
the limiting pollutant.
2.4.2 Segments Limited by Copper

Stream name Index number Description Segment
length (miles)
Integrated
Report
Category
Third Fork Creek 16-41-1-12-(2) from a point 2.0 miles
upstream of N.C. Hwy. 54
to New Hope Creek
3.9 5e
Northeast Creek 16-41-1-17-
(0.7)a
from N.C. Hwy. 55 to
Durham Triangle WWTP
3.3 5
16-41-1-17-
(0.7)b2
From Kit Creek to a point
0.5 miles downstream of
Panther Creek
3.2 4t

The segment of Third Fork Creek is entirely with the City of Durham. Category 5e indicates that
greater than 10% of samples exceeded the water quality standard, but that there was not 90%
statistical confidence of sample results.
The two segments of Northeast Creek begin within the City, flow southward and end outside city
limits in Durham County. A major tributary of this segment is Burdens Creek, which drains a portion
of Research Triangle Park, an industrial park outside city limits.
General Information about Copper
Copper is widely present. Dissolved copper more closely represents the bioavailable form of copper
than total copper. North Carolina water quality standards modified its water quality standards for
toxic metals in 2016 to change from total copper to dissolved copper when EPA approved the
standards change.
As discussed in Appendix I, Durham conducted wet weather monitoring in the 1990s to characterize
stormwater runoff for various land uses. The event mean concentrations (EMC) for total copper were
well below those previously reported by EPA in the National Urban Runoff Program (USEPA, 1983;
Whalen, et al, 1989), but were similar to residential and commercial median EMCs reported in the
National Stormwater Quality Database by Pitt.
Special studies conducted by the City that have monitored for both dissolved and total copper have
found that dissolved copper can be between 30% and 60% of total copper.

Sources of copper:
2-25

• Industrial copper manufacturing
• Metal recycling facilities, including auto salvage
• Vehicle brake pads
• Copper-based algaecides used in lakes, ponds, stormwater BMPs, pools, spas, fountains,
and evaporative cooling towers.
• Copper-containing pesticides used to control fungi and roots. Common applications include
controlling fungi on plants; serving as biocides in commercial products; and preventing rot
and mildew on wood, roofing and other outdoor surfaces.
• Corrosion by-product in boiler blowdown
• Soil erosion
• Copper in process wastewater generated from the cleaning of air conditioning unit coils by
commercial contractors
Existing NPDES Programs that address Copper:
Inspection Program: Stormwater Services began enhancing its industrial inspection program in 2008
to better focus on preventing pollution. The program currently inventories and inspects industrial (as
defined by 40 C.F.R. 122.26) and light industrial (mainly automotive service-related operations)
facilities located within City limits. The types of facilities inspected include: 1) hazardous waste
treatment, disposal, and recovery facilities; 2) industrial facilities subject to Section 313 of Title III of
the Superfund Amendments and Reauthorization Act of 1986 (SARA); 3) industrial facilities that the
City determines are contributing or have a potential to contribute a substantial pollutant loading to
the municipal storm sewer system; 4) facilities subject to the NPDES Industrial Stormwater Permit
Program; and 5) selected facilities associated with a history of illicit discharges under the City’s Illicit
Discharge Detection and Elimination Program.
Facilities subject to NPDES permitting or which report toxic releases under SARA and located in
Northeast and Third Fork Creek are listed in Table 2-7 by permit category (if applicable).
Table 2-6 Industrial Facilities in Northeast Creek and Third Fork Creek
Facility Creek Category
Permit or No
Exposure
Number
Waste Industries Northeast 08 - Transit and
Transportation NCG080845
Southeastern Freight Lines, Inc. Northeast 08 - Transit and
Transportation NCG080930
Intermont Group Third Fork 08 - Transit and
Transportation NCG080082
City of Durham Public Works
Operations Center Third Fork 08 - Transit and
Transportation NCG080776
Academy Bus Lines Third Fork 08 - Transit and
Transportation NCG080863
Wagner’s Auto Salvage Northeast 10 - Used Motor
Vehicles NCG100026
2-26

Table 2-6 Industrial Facilities in Northeast Creek and Third Fork Creek
Facility Creek Category
Permit or No
Exposure
Number
Foss Recycling Northeast 10 - Used Motor
Vehicles NCG100024
Sonoco Products, Co. Northeast 13 - Non-Metal Waste
and Scrap NCG130010
Ready Mixed Concrete Company
#17 Northeast 14 – Ready-Mixed
Concrete NCG140129
Chandler Concrete Co. Durham
Plant 603 Third Fork 14 - Ready-Mixed
Concrete NCG140095
Chandler Concrete Co. Durham
Plant 606 Third Fork 14 - Ready-Mixed
Concrete NCG140346
Thomas Concrete Third Fork 14 - Ready-Mixed
Concrete NCG140218
SCM Metal Products, Inc. Northeast
Mfr of copper powder,
tin powder, and copper
brazing paste
NCS000050
Airgas Specialty Gases Northeast
Industrial application,
specialty, and medical
gases.
NCS000046
SCIGRIP (IPS Corp.) Third Fork Mfr of structural
adhesives NCS005277
Brenntag Southeast, Inc. Third Fork Chemical distributor
UPS Supply Chain Solutions
(Healthcare Division) Northeast No Exposure (Trans-
shipping) NCGNE0731
FedEx Home Northeast No Exposure NCGNE0516
Valassis Manufacturing Company Northeast
No Exposure (50%
warehouse, 50%
printing by heatset
lithography)
NCGNE0519
Burt's Bees, Inc. Northeast No Exposure (cosmetic
and skin care products) NCGNE0603
Counter Culture Coffee Northeast No Exposure (Coffee
roasting) NCGNE0785
Classic Graphics Northeast No Exposure (printing) NCGNE1123

Based on review of TRI reporting, the largest releases of copper occurred at the SCM Metal Products
facility at 2601 Weck Drive. The website for SCM Metal Products says they are “Global leaders in the
production of copper and aluminum metal powders and their related alloys.” The Weck Drive facility
2-27

manufacturers copper powder, tin powder, and copper brazing paste. Processes include melting,
atomizing, grinding, and blending. The 2015 TRI Form R report for copper compounds (DCN
1312210006627) indicates the Weck Drive facility released 2,415 pounds by fugitive air emissions,
10,817 pounds by stack emission, 13 lbs. per year to Stirrup Iron Creek and 33 pounds to unnamed
water Body. Part of the property drains to Stirrup Iron Creek while another part drains westward to
Northeast Creek. In 2008 a special study of copper in Stirrup Iron Creek found very high copper
concentrations in three adjacent tributaries of Stirrup Iron Creek.
City Stormwater Services staff first inspected the SCM Metal Products facility in 2007. The facility
was initially covered under a NPDES Stormwater General Permit that did not require runoff
monitoring for copper. Following discussions with state NPDES permit writers pursuant to permit
renewal, the state required the facility to apply for an individual permit, and regulators included
monitoring requirements for copper.
In 2010, the City classified the facility as high risk, and inspection frequency was increased to
annual. Seven inspections have been conducted from 2010 through mid-2017. There has been no
compliance issue related to production, storage, or transportation of copper or tin products. There
have been two compliance issues related to other issues. Inspections have documented progressive
efforts to reduce exposure and to implement stormwater control measures to improve management
of copper dust. Control measures have included vacuuming copper dust off forklifts before they exit
a building; moving processes to eliminate the need for forklifts to transit from building to building;
acquiring a street sweeper to clean outside areas; and designing, constructing, and operating a
bioretention cell in the area draining to Northeast Creek, installation of high-power air filtration
systems to capture fugitive emissions, and use of tack mats at all process area egress points to limit
track-out of dusts. The facility is in compliance with its NPDES Stormwater Permit.
The SCM Metal Products facility is additionally subject to a state-issued Air Quality Permit (No.
04185R17), which covers stationary source emissions from the facility’s copper furnaces, oxidizers,
mills, grinders, powder blenders, cyclones, and brazing paste manufacturers. This air permit limits
emissions from the facility based on: particulate matter, sulfur dioxide, opacity, and “Manganese &
compounds.”
Within the Third Fork Creek and Northeast Creek watersheds, the Inspection Program also covers
five facilities NPDES-Permitted under “Transit and Transportation,” two facilities involved in “Used
Motor Vehicles,” and four “Ready-mixed Concrete” facilities. In the case of the Waste Industries
facility, two operations are conducted: 1) construction, demolition, and municipal solid waste
transfer; and 2) maintenance of fleet vehicles (“Transit and Transportation”).
Another focus of the City’s Inspections Program is routine inspection of high-risk automotive service
facilities. The City’s Stormwater Management and Pollution Control Ordinance requires that nearly all
maintenance vehicle activities at such facilities, including brake service and fluid changes, must be
performed in covered bays or indoors. The ordinance also requires that automotive fluids and oily
engine parts are properly stored so that they do not contact rainwater or runoff, and that such
facilities maintain spill response kits meeting City Guidelines. Businesses that are found to be well-
managed, having resources and procedures in place to manage wastes and prevent pollution, are
deemed low priority. High- and medium-risk facilities are inspected more frequently to assess
maintenance activities, storage of used vehicle parts, handling and storage of wastes, spill cleanup,
good housekeeping, overall risk, and to ensure compliance with ordinance requirements.
Illicit Discharge Detection and Elimination – The City’s ambient monitoring program monitors for both
dissolved copper and total copper, while illicit discharge program uses various field analytical kits
useful for tracing sources where ambient monitoring indicates specific sources. Sources identified by
the IDDE program have most often involved discharges where copper sulfate has been used to
control algae; examples include discharges from decorative fountains and from rooftop evaporative
cooling tower-type air conditioners. The illicit discharge program has also found instances where
2-28

owners of structural stormwater control measures have applied chemicals to control algae, and has
referred these cases to the Stormwater Development Review group. Most often these investigations
have involved the use of non-toxic, light-blocking “aquacludes” but occasionally copper sulfate has
been used.
Street Sweeping – The City has maintained a street sweeping program utilizing regenerative air
sweepers to remove both debris and the fine particles that contain metals, hydrocarbons, and other
pollutants. As shown in Table 2-8, this program annually removes about 3,500 tons of materials
from city streets, municipal operations, and
surface parking lots.
Household Hazardous Waste Collection
Center – The City has been operating a
household hazardous waste collection
facility to facilitate proper disposal of a
wide range of hazardous wastes. The facility
accepts pesticides and empty pesticide
containers, including copper-based
pesticides.
Erosion and Sediment Control – Copper is
an essential plant nutrient and is present in
soil in trace amounts. Soil erosion is a
source of copper entering waterways. The
North Carolina Sedimentation Commission
has authorized the Durham County Erosion
and Stormwater Division to implement the
Sedimentation Pollution Control Act within
all of Durham County, including the City of Durham.
Post-construction requirements – Total copper consists of particulate and dissolved fractions as
discussed above. Stormwater Control Measures commonly used in the City of Durham to meet post-
construction ordinance requirements remove pollutants primarily through settling and mechanical
filtration, which will remove a portion of the particulate fraction. The City of Durham’s post-
construction ordinance also requires that developments mitigate increases in peak flow for the one-
year storm, with the objective of preserving channel stability. These measures help address soil
erosion as a source of copper.
The City’s Stormwater Development Review group prohibits the use of chemical treatment, including
the use of copper sulfate as an algaecide, in structural SCMs without written authorization. To help
educate consultants involved in design and maintenance inspection of SCMs, the Development
Review group has hosted seminars on pond management.
Water Quality Monitoring – The City has been monitoring dissolved metals in some fashion since
2003. As state regulators moved toward adoption of water quality standards based on dissolved
metals, the City altered its protocols to incorporate field filtering in anticipation that the state would
employ field filtering to assess metals compliance with the new standard. Durham’s urban streams
typically have elevated hardness under baseflow conditions due to groundwater recharge. Dissolved
copper is often below the hardness adjusted continuous chronic criterion EPA has established for
copper. Development of state protocols for measuring dissolved copper should aid Durham’s efforts
to identify sources and to work with responsible parties. Implementation of monitoring under the new
protocols may result in changes in listing status.
Regulatory Changes - Current 303d listings for copper are based on a prior water quality action level
standard for total copper of 7 μg/L. More recently, the State of North Carolina has replaced the total
Table 2-7 Street Sweeping in City of Durham, by
Year
Fiscal
Year Curb Miles Swept
Sweeping
Material
Disposed, tons
2011-12 17,853 2,851
2012-13 12,806 2,712
2013-14 20,676 3,796
2014-15 28,892 4,695
2015-16 31,660 3,350
2016-17 21,117 2,856
Average 22,167 3,377
2-29

copper standard with a water quality standard for dissolved copper that is hardness-dependent.
NCDEQ is conducting limited ambient monitoring for dissolved metals while state regulators develop
protocols for monitoring dissolved metals. NSQD reports mean dissolved copper concentrations of
7.0 μg/L at residential sites, 7.57 μg/L at commercial sites, and 8.0 μg/L at industrial sites (Pitt et
al., 2005). Once monitoring protocols are in place, the City of Durham will evaluate compliance
compared to the current dissolved standard, and will assess the likelihood that monitoring for
additional parameters may result in application of the EPA biotic ligand model.

2.4.3 Segments Limited by Zinc
Stream name Index number Description Segment
length (miles)
Integrated
Report
Category
Third Fork Creek 16-41-1-12-(1) from source to a point 2.0
miles upstream of N.C.
Hwy. 54
5.2 5
Northeast Creek 16-41-1-17-
(0.7)b1
from Durham Triangle
WWTP to Kit Creek a
3.3 5
a This segment is outside city limits, but several small city tributaries discharge to this segment,
including the one draining Parkwood Lake)
General Information about Zinc
Zinc is widely present, but higher concentrations are associated with commercial and industrial uses.
North Carolina water quality standards modified its water quality standards for toxic metals in 2016
to change from total zinc to dissolved zinc.
As discussed in Appendix I, Durham conducted wet weather monitoring in the 1990s to characterize
stormwater runoff for various land uses. The event mean concentrations (EMC) for total zinc were
well below those previously reported by EPA in the National Urban Runoff Program (USEPA, 1983;
Whalen, et al, 1989), but for commercial land uses Durham’s EMC for total zinc was higher than the
median EMC reported in the National Stormwater Quality Database by Pitt, while being similar to
median EMCs for residential and industrial land uses.
It is worth noting that Third Fork Creek and Northeast Creek were listed as impaired based upon an
action level for total zinc of 50 μg/L. This has been replaced by a hardness-based water quality
standard for dissolved zinc. The City of Durham has monitored its streams for both total and
dissolved zinc and has found that most of the zinc in Durham’s streams is in particulate form, rather
than dissolved. Rain Catchers monitoring suggests that most of the zinc in Durham’s stormwater is
also in particulate form.
Sources of zinc:
Major Sources: The major sources of zinc in stormwater runoff are:
• Outdoor zinc surfaces (especially galvanized surfaces) and
• Tire wear debris.
Outdoor zinc surfaces include:
• Galvanized materials on roofing surface (ductwork, HVAC equipment, valley gutter and
flashing)
2-30

• Galvanized fencing
Minor sources that can be locally important include:
• Pesticides (zinc moss killer, often applied to sidewalks
• Fertilizers (some have unusually high zinc content)
• Cleaners/surface preparation chemicals used before painting metal surfaces
• Wood treated with preservatives containing zinc (AZCA or zinc naphthenate)
• Wind-driven re-suspension of particles
• Anticorrosion paint
• Metal culverts
• Potable water discharges where zinc poly-phosphate is used as a corrosion inhibitor.
• Zinc in process wastewater generated from the cleaning of air conditioning unit coils by
commercial contractors
Higher concentrations are found in commercial and industrial runoff compared to residential runoff.
This appears to be associated with higher use of galvanized fencing and zinc surfaces on building
rooftops, combined with more tire wear debris from vehicles, at commercial and industrial facilities.
Existing NPDES Programs addressing Zinc:
Street Sweeping – The City has maintained a street sweeping program utilizing regenerative air
sweepers to remove both debris and the fine particles that contain metals, hydrocarbons, and other
pollutants. This program generally removes 3,482 tons of materials from city streets, municipal
operations, and surface parking lots.
Inspection Program: NSQD and City of Durham both found higher concentrations in stormwater from
industrial and commercial land use than from residential.
Stormwater Services inspection program currently inventories and inspects industrial (as defined by
40 C.F.R. 122.26) and light industrial (mainly automotive service-related operations) facilities
located within City limits, as described in greater detail in the section above on copper. Categories of
permitted facilities in Northeast Creek and Third Fork Creek include Transit and Transportation, Used
Motor Vehicles, Non-metal Waste and Scrap, and Ready-Mixed Concrete. The major source of zinc at
these facilities is likely to be outdoor zinc surfaces.
Industrial facilities reporting Toxic Release Inventory (TRI) releases {aka facilities subject to Section
313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA)}, and
industrial activities subject to stormwater permit requirements. Inspected industrial facilities include
auto salvage recyclers, metal recyclers and a metallurgy manufacturer. Zinc releases were reported
in Durham County by SCM Metals and Burt’s Bees. The SCM Metal Products facility at 2601 Weck
Drive reported releases of zinc compounds for 2015 of 2.78 pounds by fugitive air emissions, 75.43
pounds by stack emission, 1.03 lb. per year to Stirrup Iron Creek, and 2.65 pounds to an unnamed
water body to Northeast Creek by stormwater runoff. The Burt’s Bees facility at 701 Distribution
Drive reported releases of zinc compounds of 1 pound of zinc compounds by fugitive air emissions
for 2015. Burt’s Bees has a no exposure permit.

The Inspection Program also conducts routine inspections of high risk automotive service facilities.
The City’s Stormwater Management and Pollution Control Ordinance requires that nearly all
maintenance vehicle activities at such facilities, including brake service and fluid changes, must be
2-31

performed in covered bays or indoors, and wastewater from vehicle and tire washing must be
captured and properly disposed of. Businesses that are found to be well-managed, having resources
and procedures in place to manage wastes and prevent pollution, are deemed low priority. High- and
medium- risk facilities are inspected more frequently to assess maintenance activities, storage of
used vehicle parts, staging of wastes, spill cleanup, good housekeeping, overall risk, and to ensure
compliance with ordinance requirements.
Household Hazardous Waste Collection Center – The City has been operating a household hazardous
waste collection to facilitate proper disposal of a wide range of hazardous wastes. The facility
accepts pesticides and empty pesticide containers, including zinc-based pesticides. The facility also
accepts toxic cleaners, unused wood preservatives, and unused paint, including zinc-rich anti-
corrosion paint.
Post-construction Peak Flow Control requirements – Total zinc consists of particulate and dissolved
fractions. SCMs commonly used in the City of Durham to meet post-construction ordinance
requirements remove pollutants primarily through settling and mechanical filtration, which will
remove a portion of the particulate fraction.

2.4.4 Segments Limited by Polychlorinated biphenyls (PCBs)
Stream name Index number Description Segment
length (miles)
Integrated
Report
Category
Little Brier Creek 27-33-4-1 from source to Brier Creek 5.3 (1.0 mile
in the City)
5

General Information about PCBs
Polychlorinated biphenyls (PCBs) were identified as persistent organic pollutants and subsequently,
PCB production was banned by the United States Congress in 1979. PCBs were once widely
deployed as dielectric and coolant fluids in electrical apparatus. Because of their stability and
longevity, PCBs remain in use, being replaced slowly.
Fish consumption advisories have been issued by the Occupational and Environmental Epidemiology
Branch, N.C. Division of Public Health for polychlorinated biphenyls (PCBs) in Crabtree Lake and for
its tributaries, Brier Creek and Crabtree Creek, in Wake County. An advisory was also issued for Little
Brier Creek downstream of Brier Creek Parkway in Wake County. Approximately 1 mile of Little Brier
Creek is in the City of Durham.
Sources of PCBs:
The PCBs in Crabtree Lake and its tributaries are from the Ward Transformer Superfund Site at 6852
Mount Herman, Raleigh, NC 27614. The Ward Transformer Company operated on this site from
1964 until 2006.
Existing NPDES Programs addressing PCBs:
The source of the PCBs in Little Brier Creek is from legacy contamination originating at a location
downstream of Durham and well outside the city’s jurisdictional area. The segment of Little Brier
Creek included on the 303(d) list is not included in the fish advisory but appears to have been listed
out of concern that fish can move upstream after being exposed to PCBs.
The City of Durham is not authorized to prevent fish from migrating upstream and is not undertaking
actions to address this impairment.
2-32

2.4.5 Segments Limited by Dissolved Oxygen (DO)
Stream name Index number Description Segment
length (miles)
Integrated
Report
Category
Little Lick Creek 27-9-(0.5) from source to a point 0.4
mile upstream of Durham
Co SR 1811 (Patterson
Road)
7.2
(2.7 in City)
5
UT 2 to Little Lick
Creek
27-9-(0.5)ut2 from source to Little Lick
Creek
2.4 5
New Hope Creek 16-41-1-(11.5)a
16-41-1-(11.5)b
from a point 0.3 mile
upstream of Durham Co
SR 2220 (Old Chapel Hill
Road) to I-40
3.9
(2.7 in City)
4c
Third Fork Creek 16-10-1-12(2) from a point 2.0 miles
upstream of N.C. Hwy 54
to New Hope Creek
9.1
(all in city)
5
Northeast Creek 16-41-1-17-
(0.7)a
from N.C. Hwy 55 to
Durham Triangle WWTP,
3.3 miles
3.3
(2.8 in City)
4c

Four streams in Durham have stream segments that are water quality limited by low dissolved
oxygen. Segments of New Hope Creek and Northeast Creek are category 4c.
Category 4c indicates that the criteria were exceeded, but that a non-pollutant is the reason for the
exceedance. Segments of Third Fork Creek, Little Lick Creek and an unnamed tributary of Little Lick
Creek are included in Category 5.
General Information about Oxygen Consuming Materials
As discussed in Appendix I, streams in forested watersheds receive inputs of organic matter in the
form of leaves deposited on the water surface. As these materials decay, they can use up oxygen
needed by fish and other aquatic organisms. Such streams generally have high levels of dissolved
oxygen because organic inputs are relatively low, the streams are well shaded, and stream recharge
together with flow confined to a thalweg results in velocities supporting reaeration. The movement of
the water disrupts surface tension and enhances reaeration in flowing streams, compared to still
water. When water is flowing, reaeration provides continual resupply of oxygen that is consumed.
In urban areas, impervious surfaces reduce groundwater recharge, and underground utility trenches
serve as dewatering conduits that lower the water table, both of which reduce stream recharge.
Furthermore, urban streams have often undergone modifications that increase water temperature
(reduction in shading) and reduce velocity. Channel modifications have further reduced the velocity
of water flow in streams. Large sections of urban streams have usually been straightened and
dredged, or have down-cut. The channel bottom is often constrained by buried pipes (water, sewer),
and culverts that result in sections of channel with low slope or gradient. Instream impoundments
and beaver dams back up stream flow into stagnant pools. Removal of riparian tree canopy results in
warmer water that can hold less oxygen than cooler water. These changes all combine to significantly
reduce reaeration.
2-33

Streets provide surfaces that collect leaves which are carried to local streams. Other sources of
oxygen- demanding materials include illicit discharges from grey infrastructure, discharges of
dumpster juice and cooking grease at food service facilities, and illegal dumping of yard wastes.
These issues are compounded in the Triassic Basin, which has soils of low permeability, and streams
have the lowest potential for sustained based flows in the Cape Fear River Basin (USGS 2001).
Segments of perennial streams in Durham often dry up during the summer, as observed during
ambient monitoring. The low baseflow results in much less reaeration than occurs in streams with
higher baseflow.
Sources, causes of low dissolved oxygen:
• Hydrologic modification is the primary factor in persistent low dissolved oxygen
conditions in streams listed as 4c, and possibly others; contributing factors include:
o Beaver dams, waterfowl impoundments, culvert plunge pools resulting in
stagnant water
o Culverts, water and sewer pipes that serve as grade controls
o Water fowl impoundments (New Hope Creek - 3 , Third Fork Creek - 1)
o Incised streams, reduced recharge
• Low stream gradient in Little Lick Creek
• Reduction in canopy cover resulting in higher water temperature
• Illicit disposal of yard wastes
• Leaves, grass clippings, pet wastes carried into streams from streets and other
impervious surfaces
• Illicit charges from grey infrastructure,
• Illicit discharges of dumpster juice
• Illicit discharges of cooking grease at food service facilities
Watershed Planning and Modeling – As presented in Table 2-5 above, the City of Durham has
completed watershed plans for Third Fork Creek, Northeast Creek, and Little Lick Creek, which are
listed for low dissolved oxygen. Third Fork Creek is tributary to the segment of New Hope Creek that
is also listed for low dissolved oxygen. The watershed models used in the projects are capable of
addressing a range of pollutant but they do not model in-stream effects such as reaeration and
sediment oxygen demand as necessary to address dissolved oxygen.
As a follow-up to development of the Northeast Creek Watershed Plan, the City retained Tetra Tech
to develop a water quality model that used the calibrated watershed model for loading inputs. The
final report (Tetra Tech, 2013) indicates that the calibrated WASP water quality model does a good
job of capturing the seasonal trends, magnitudes, and range of observations for dissolved oxygen.
The model ended up being fairly insensitive to ultimate carbonaceous biochemical oxygen demand
(CBODu) and ammonia, both of which exert oxygen demand and are therefore are normally targets of
regulatory requirements where low DO is of concern.
The primary cause of low DO in Northeast Creek is believed to be associated with
hydromodification, attributed to changing patterns of flow, depth and velocity and the
resulting parameters they impact (e.g. reaeration and residence time). The modeled portion
of Northeast Creek contains three known beaver dams and three roadway culverts.
Collectively these impoundments alter the hydrodynamics, slowing velocity, increasing
residence time for oxygen-demanding substances, decreasing reaeration and thereby
2-34

impacting the condition of water quality. Baseflow conditions are also relatively low, likely
the result of the significant level of development and land use/land cover change. . . and
partly because of low Baseflow in general in Triassic Basin soils, which exacerbates the low
DO conditions during Baseflow periods.
The report concludes that reducing upland pollutant loading is not considered to be significantly
beneficial with regard to DO improvement.
Based on discussions between the City and state regulators, the City formally requested that the
dissolved oxygen listing for Northeast Creek on the state 303(d) list be changed from Category 5
requiring a TMDL to Category 4c recognizing that impairment is due a non-pollutant
(hydromodification). This request was approved.
As indicated above, beaver dams and road culverts are also found in all four stream segment. In
addition, Little Lick Creek and New Hope Creek have low gradients and have the highest percentage
of channel segments that are rated poor for stream stability. The New Hope Creek segment includes
two large water fowl impoundments that cover roughly two-thirds of the segment. The impoundments
are operated seasonally, holding back water during the winter. While they are impounding water,
they also accumulate sediment and organic material.
Based on the findings in Northeast Creek, and the conditions in the other stream segments, it is
likely the hydromodification is the principal factor in low dissolved oxygen. Water quality models have
not been developed to assess and confirm this hypothesis.
The City maintains NPDES programs that help to minimize sources of ammonia and other oxygen-
demanding materials entering Northeast Creek.
Existing NPDES Programs that Target Oxygen Consuming Materials
Public Education – Stormwater education staff use various means to educate city residents about
proper disposal of grass clippings and other yard wastes, including newspaper articles, flyers, and
Clean Water Education Partnership videos and PSAs. Campaigns have targeted restaurants with
flyers including with stormwater utility bills and will a series of postcards regarding waste handling
practices (dumpster juice and cooking grease).
IDDE - Stormwater IDDE staff investigate concerns by city residents about discharges of sewage,
grease, dumpster juice, and other non-stormwater discharges. Staff also investigate improper
disposal of yard wastes. City’s illicit discharge program also conducts dry weather outfall screening
and uses various field tests, including tests for ammonia and detergent to screen for illicit
discharges. In addition to being general indicators of pollution, both detergent and ammonia are
oxygen-demanding substances.
Non-regulatory programs that address Hydromodification
Various city partners have lead projects to implement stream restoration projects on stream
segments within and adjacent to the City of Durham, and the City has led a project that recently
restored a segment of Third Fork Creek.
2.4.6 Segments Limited by Turbidity
Stream name Index number Description Segment
length (miles)
Integrated
Report
Category
Third Fork Creek 16-41-1-12-(2) from point 2.0 miles
upstream of NC Hwy 54 to
New Hope Creek
3.9
(all in City)
4i
2-35

Little Lick Creek 27-9-(0.5) from source to a point 0.4
mile upstream of Durham
Co SR 1811 (Patterson
Road)
7.2
(2.7 in City)
5

General Information about Turbidity and Sediment
Turbidity is a measure of light scattering due to fine particles in the water. The particles that cause
light scattering are typically clay particles. Because they are so small, clay particles do not readily
settle under quiescent conditions.
Because turbidity measures light scattering, it is not measuring the concentration of a pollutant, and
it cannot be translated into a pollutant mass, as necessary to develop a TMDL. EPA guidance
suggests that in many cases it can be appropriate to use sediment as a surrogate for turbidity. The
rationale for using sediment is that turbidity and sediment usually are derived from soil erosion. The
parameter most frequently monitored to assess sediment is total suspended solids or TSS. There is
often a correlation between TSS and turbidity, although when such a relationship is found it is unique
to a particular sampling location.
The North Carolina Division of Water Resources addressed past turbidity violations in Third Fork
Creek by expressing the TMDL associated with the segment listed in the table in terms of the load of
total suspended solids (TSS).
Locally identified sources of turbidity and sediment include the following:
• Channel erosion is the largest single source of sediment and turbidity in most urban streams
• Construction site runoff can be a locally significant source
• Installation of buried utilities (e.g. fiber optic)
TSS is frequently monitored in both stormwater runoff and in streams and other water bodies. It has
been widely reported that TSS load measured in stormwater runoff is typically less than half the TSS
load in urban streams. These results indicate that bed and bank erosion typically are larger sources
of sediment than stormwater runoff.
Stormwater runoff monitoring documented in the US. National Stormwater Quality Database (NSQD)
found median TSS concentrations of 49 mg/L at residential sites, 43 mg/L at commercial sites, and
81 mg/L, at industrial sites respectively (Pitt et al., 2005). Monitoring by the City of Durham
Stormwater Services (City of Durham, 1999) determined event mean concentrations for TSS in
residential, commercial and industrial runoff to be 16, 179, and 178 mg/L, respectively. The Soil
Survey of Durham County (Kirby, 1976) characterizes many soils in Durham as “erodes easily.” The
highly erodible nature of Durham soils, particularly those associated with Triassic Basin geology, may
explain why Durham’s runoff has higher TSS concentrations than the NSQD.
The City of Durham application for permit renewal (City of Durham, 1999) determined the annual
sediment load from stormwater runoff in the Third Fork Creek watershed was estimated to be
1,894,166 pounds TSS per year, using the event mean concentrations together with estimates of
annual stormwater runoff calculated using Schueler’s Simple Method (Schueler, 1987, also 15A
NCAC 02H .1002 Definitions), together with land use (impervious cover) and annual rainfall. The TSS
in Durham’s runoff is much lower than instream measurements.
The City has been reporting estimates of sediment load in stream discharge in Third Fork Creek in
the City’s Annual Reports under the Water Quality Recovery Program for the Third Fork Creek TMDL.
The Mean Annual Loads for the period 2010 through 2014 are summarized in table 2-10.
2-36

Comparing the watershed load (1,894,166 pounds TSS per year) to the average of the annual loads
for the five year period from 2010 to 2014, stormwater runoff accounts for 37% of the sediment
carried by Third Fork Creek. This supports findings by others [e.g. Fraley-McNeal (2014); Schueler
(2015)] that channel erosion is a significant source of sediment in urban streams, and is often the
largest source.
As reported in the discussion of dissolved oxygen above, the Third Fork Creek Watershed Plan found
that 25% of the watershed is impervious. It found that 35% of the channel rated as fair for channel
stability and 19% rated as poor. The relatively high impervious cover results in higher peak flow for
the one-year storm, resulting in increased erosive forces on the unstable channel segment.
The Little Lick Creek Watershed Plan found that 12% of the watershed is impervious and that 43% of
channels rated as fair and 52% rated as poor. The level of development is modest, but the high
percentage of unstable channels results in a comparatively large contributing area. Unstable
channels were encountered in catchments that are currently forested and lack built upon areas. In
some cases, channels appeared to have been dredged and straightened in an effort to enhance
drainage and allow use of the floodplain.
Below is a discussion of the City’s existing programs that address efforts to address stormwater
runoff pollutant contributions of turbidity and sediment. The City is also undertaking efforts to
address other sources of sediment, such as from channel erosion.
Watershed Planning and Modeling - The City of Durham worked with consultants to complete a
watershed plan for Little Lick Creek in 2016. Plan development involved fieldwork as well as desktop
GIS analysis and watershed modeling. The field work includes stream assessment of 26 miles of
channel, identification of potential pollution sources, assessment of existing SCMs, assessment of
stream restoration opportunities, assessment of potential retrofit locations, and identification of
priority areas for land preservation. A SWMM watershed model and a WARMF watershed model were
developed and or updated and calibrated to available data.
As part of the Little Lick Creek watershed plan, the City began to monitor stream bank erosion in
multiple locations using bank pins. Bank pins were set in the Third Fork and Little Lick Creek
watersheds, as well as watersheds of four other creeks in the City. Although this study is ongoing, a
summary of monitoring for the first year is available. The Bank Erosion Hazard Indices (BEHI) for the
two sites in the Third Fork Creek watershed were Extreme. The BEHIs for the two sites in the Little
Lick Creek watershed were High. After one year of
monitoring, the annualized bank erosion rate was 0.72
ft/yr at one of the Third Fork Creek sites and 0.08 ft/yr at
one of the Little Lick Creek sites. Annualized bank erosion
rates were not calculated for the other two sites.
Existing NPDES Programs that address Sediment
Illicit Discharge Detection and Elimination – Turbidity is
measured during the monthly ambient monitoring
program, with anomalous results triggering an
investigation. Stormwater Services responds to concerns
of residents regarding sediment in City streets, storm
drains, and creek. City engineering and building inspectors
have received training on reporting illicit discharges,
particularly those related to construction and utility
installation. The city has developed guidance documents
for fiber optic utility installation and addresses issues
through the IDDE enforcement process.
Table 2-8 Annual Sediment
Discharge in Third Fork Creek

Year Mean Annual Load (lbs)
2010 2,953,334
2011 3,687,840
2012 1,749,435
2013 8,964,669
2014 8,196,185
2015 4,137,266
2016 8,449,450
2017 5,251,791
2-37

Street Sweeping – The City has maintained a street sweeping program utilizing regenerative air
sweepers to remove both debris and sediment. This program generally removes 3,482 tons of
materials from city streets, municipal operations, and surface parking lots.
Construction site runoff control – Durham County has been authorized by the NC Sedimentation
Control Commission to implement the NC Sedimentation Control Act throughout Durham County,
including within the City of Durham. This program includes plan review and approval, inspection and
enforcement. The City’s illicit discharge program coordinates with the county program and also
conducts independent enforcement when sediment is entering a city street, storm drain or stream.
2.4.7 Segments with Limited Fish Community
Stream name Index number Description Segment
length (miles)
Integrated
Report
Category
Ellerbe Creek 27-5-(0.3)

27-5-(0.7)
From source to I-85 bridge

From I-85 bridge to a point
2.2 miles upstream of
Durham co SR 1636
(Glenn Road)
6.1
(all in City)
5.9
(4.2 in City)
5

General information about Fish Community
Biological impairment is rarely attributable to a specific pollutant. In the absence of specific sources
like an industrial discharge, it is often difficult to assign likely causes and sources. Most often
biological impairment is due to the complex interaction of multiple stressors. Pollutants may act as
stressors but many stressors are not pollutants. There is not a specific Pollutant of Concern related
to the 303(d) listing for the fish community in Ellerbe Creek.
In Ellerbe Creek, causes of impaired fish community may include historic dredging and
channelization resulting in habitat destruction, lack of riparian vegetation, lack of shade, and
disruption of sediment delivery. An impaired aquatic insect community also affects the fish
community. The Ellerbe Creek watershed is largely built-out but is undergoing redevelopment. Prior
watershed development has resulted in flow alteration and increased flashiness.
Ellerbe Creek was dredged and channelized by the US Army Corps of Engineers in the late 1950s to
reduce hazards to life and property from flooding. Dredging disconnected the channel from its
historic floodplain. The trapezoidal shape \___/ imposed on the channel cross-section provided
efficient transmission of runoff away from developed areas. The wide, flat channel bottom lacks the
pool-riffle sequence found in many natural channels. As a condition of this flood control project, the
Corps of Engineers required that the city remove woody vegetation from the channel banks. Woody
vegetation on channel banks helps to anchor soil and resist erosion. Woody vegetation also provides
shade that helps to reduce average water temperatures. Aquatic organisms are particularly stressed
by exposure to high water temperatures for long periods of time. Wide, flat channels lacking pools for
fish to hide and lacking shade are particularly subject to warmer water temperatures. In wide, flat
channels sediment tends to build up during base flow conditions, and then wash out during high
flows.
The City conducted a fish study of the Eno River and Ellerbe Creek as part of the Eno River
Watershed Plan. Fieldwork in 2017 included surveys at on Ellerbe Creek at Glenn Road {SR 1636
(36.0597, -78.83268), and at Midland Terrace (36.02212, -78.8704). The stream at Midland
2-38

Terrace is part of the channel section that was highly modified by straightening, dredging, and
reshaped into a trapezoidal cross-section. If a Fair or Poor NCIBI rating is determined for Ellerbe
Creek, a preliminary stressor study will be conducted to evaluate existing information and the
potential for impacts to the fish community.
Fish community assessments followed NCDEQ protocols (NCDEQ, 2013) for NCIBI and habitat
ratings. Field results indicate that both sites are impaired with Midland Terrace rated poor, and
Glenn Road rated Fair. Lack of species abundance for darters and suckers, lack of intolerant species
and high percentage of tolerant, insectivorous and diseased individuals resulted in lower metric
scores. The Ellerbe Creek Midland Terrace site had the lowest total fish count (n=243) and species
richness. Habitat scored 41 out of 100 total points. Lower scoring parameters are attributed to
homogeneous sand dominated substrate, low habitat variety, significant bank erosion, and breaks
for light penetration in the tree canopy. Low habitat variety is largely a reflection of infrequent or
absent pool and riffle habitats. Lack of woody vegetation along the banks reduces rootlets along the
water’s edge, contributes to light reaching the surface of the water. Lack of woody vegetation also
means there are less cover and habitat for fish. The Fair and Poor NCIBI ratings for Ellerbe Creek are
the basis for a preliminary stressor study that will be completed in 2017 to evaluate existing
information and the potential for impacts to the fish community.
The City has coordinated with the Corps of Engineers to place the Ellerbe Creek Flood Control Project
in inactive status and as a result, the City is no longer removing vegetation from the channel banks.
Several stream restoration projects have been completed to improve sediment delivery, increase in-
stream habitat, and provide riparian vegetation. The City participated with the North Carolina
Ecosystem Enhancement Program (now the Division of Mitigation Services), the Ellerbe Creek
Watershed Association (ECWA), and the Durham Soil and Water Conservation District (DSWCD) to
develop a watershed plan for Ellerbe Creek in 2001, completed as a desktop exercise and largely
with existing staff resources. A more comprehensive watershed plan was developed by a team of
consultants in 2009 and included identification of specific projects to improve water quality. `
The North Carolina Ecosystem Enhancement Program and the Ellerbe Creek Watershed Association
have led projects (with cooperation from the City of Durham) to design and stabilize segments of
Ellerbe Creek that were deeply incised, with channel banks having no vegetation or other means to
stabilize steeply-sloped, bare soil. The City has been working with both ECWA and DSWCD to
implement residential retrofitting projects in an effort to raise awareness.
Existing NPDES Programs that address Fish Community
The City has adopted peak flow requirements for land development projects to help mitigate impacts
from development.
2.4.8 Segments with Limited Aquatic Insect Community (Benthic Macroinvertebrates)

Stream name Index number Description Segment length
(miles)
Integrated
Report
Category
Ellerbe Creek 27-5-(2) from a point 0.2 miles upstream
of Durham Co SR1636 (Glenn
Road) to Falls Lake, Neuse River
0.5 5
Little Lick Creek 27-9-(0.5) from source to a point 0.4 mile
upstream of Durham Co SR
1811 (Patterson Road)
7.2
(2.7 in City)
4s
Lick Creek 27-11-(0.5) from source to Durham Co SR
1809 (Southview Road)
6.5
(3.1 in City)
5
New Hope Creek 16-41-1-(11.5)a

From a point 0.3 mile upstream
of Durham Co SR 2220 to
0.4
(all in City)
5
2-39

Durham Co SR 2220 (Old
Chapel Hill Road)
16-41-1-(11.5)b From Durham Co SR 2220 to I-
40
3.5
(2.3 in City)
5
16-41-1-(11.5)c From I-40 to a point 0.8 mile
downstream of Durham Co SR
1107 (Stagecoach Road)
4.0
(0.3 in City)
4c
Third Fork Creek 16-41-12-(1) From source to a point 2.0 miles
upstream of NC Hwy 54
5.2
(all in City)
4s
16-41-12-(2) From a point 2.0 miles
upstream of NC Hwy 54 to New
Hope Creek
3.9
(all in City)
4s
Little Creek (Orange
County
16-41-1-15-(0.5) From source to a point 0.7 miles
downstream of Durham Co SR
1100 (Farrington Road)
4.9
(1.4 in City)
5

General information about Benthic Invertebrate Community
As indicated in the discussion of fish community above, biological impairment is rarely attributable to
a specific pollutant in urban streams. Most often biological impairment is due to the complex
interaction of multiple stressors. Pollutants may act as stressors but some of the more important
stressors are not pollutants.
The Urban Water Consortium-Stormwater Group (which includes Durham, Raleigh, Fayetteville,
Wilmington, Charlotte, Greensboro, Winston-Salem, High Point, and Burlington) has funded work to
further explore the causes related to benthic outcomes in urban streams. Camp 2015 used
respirometry to measure respiration rates of individual insect larvae in real time, evaluating resting
rates at given temperature and also changes in metabolic rates over a 10-degree C temperature
increase. The work also investigated thermal biology of rearing temperature. A niche model was used
to determine thermal optima. The results indicate that organisms handle short-term elevated
temperatures but that organism reared at temperatures higher than the optima have higher oxygen
consumption on a per mass basis, and over time have lower body weight and reduced reproduction.
Benthic impairment is strongly associated with poor habitat, but identifying other factors has been
more elusive. Identifying pollutant stressors using available data has not yielded useful results. An
improved understanding of stressors is critically important in part because implementation of
stormwater control measures has not been effective at protecting benthic communities.
Numerous studies have correlated poor benthic community outcomes with impervious surface
coverage, population, road density, and other indicators of development. Maintaining natural land
cover, preserving riparian corridors, and limiting impervious surface have been correlated with a
higher likelihood of healthy benthic communities. Horner, 1999 found that “best biological health is
impossible unless human presence is very low and the natural vegetation and soil systems are well
preserved near streams and throughout watersheds.”
All of the urban streams listed for benthic community in Durham have poor instream habitat.
Substrate is generally silty material, and rock is rare. Streams are generally incised, meaning the
channel bed has dropped. As a result, the stream is disconnected from its floodplain. A significant
percentage of channels are rated poor or fair for stream stability, indicating they have high potential
for erosion. High flows do not spill out onto the floodplain where they will slow down but instead, are
confined to the channel where they act on banks that are often bare.
Benthic community and fish community are means of assessing compliance with NCAC 15 A 2B
.0202 (11), where biological integrity is defined as “...the ability of an aquatic ecosystem to support
and maintain a balanced and indigenous community of organisms having species composition,
diversity, population densities and functional organization similar to that of reference conditions.” All
of the stream segments listed for benthic community are located in the Triassic Basin Physiographic
2-40

region of North Carolina. Triassic Basin geology and soils are markedly different than geology and
soils in the Piedmont Physiographic region.
The hydrology of Triassic Basin streams is also vastly different. USGS (1998) assessed low-flow
characteristics of streams in the Cape Fear River Basin. Stream flow site underlain by Carolina Slate
Belt and Triassic Basin were found to have zero or minimal 7-day, 10-year low flow (7Q10). The
report concludes that for ungagged streams in the Slate Belt streams draining 5 square miles or less
may have zero or minimal 7Q10 stream discharges, while the Triassic Basin has a much higher
threshold with streams draining 35 square miles as likely to have zero or minimal flow. The drainage
area of five of the six streams is below this threshold.
The North Carolina Department of Environmental Quality has determined that it does not have
appropriate criteria to rate streams in the Triassic Basin based on benthic macroinvertebrate
communities and no longer conducts assessments in these streams.
It appears likely that Triassic streams with highly urbanized watersheds would be impaired if
assessed against reference Triassic conditions. Schueler (2003) has discussed that most stream
quality indicators decline when impervious cover exceeds 10%, with severe degradation expected
beyond 25% impervious cover. However, without appropriate reference conditions, there is no way to
demonstrate compliance with aquatic life use support in the City’s Triassic Basin streams.
Existing Programs that address the Aquatic Insect Community
Watershed Planning and Modeling - The City participated with the North Carolina Ecosystem
Enhancement Program, the Ellerbe Creek Watershed Association (ECWA), and the Durham Soil and
Water Conservation District (DSWCD) to develop a watershed plan for Ellerbe Creek in 2001. This
wascompleted as a desktop exercise and largely with existing staff resources. A more comprehensive
watershed plan was developed by a team of consultants in 2009, and including identification of
specific projects to improve water quality.
The City has coordinated with the Corps of Engineers to place the Ellerbe Creek Flood Control Project
in inactive status. Several stream restoration projects have been completed to improve sediment
delivery, increase in-stream habitat, and provide riparian vegetation. The City has adopted peak flow
requirements for land development projects to help mitigate impacts from development.
The City has been working with both ECWA and DSWCD to implement residential retrofitting projects
in an effort to raise awareness.

3-41

3 Existing Water Quality Programs
This section summarizes the history of water quality protection and the evolution of water quality
programs in Durham. This information is included for reference. The city’s program to comply with
NCS0000249, including the measures in Part II Sections B through J, is provided in Section 7 of this
Stormwater Management Plan.
3.1 Local Programs
The City initiated efforts to develop water quality programs for its forthcoming Phase I Stormwater
Permit in 1991. New efforts included monitoring in urban streams, dry weather outfall
inspection/screening for illicit discharges, and wet weather studies to characterize stormwater runoff
quality from a range of land uses. As described below, these studies either have been completed or
have been enhanced and expanded. In addition, other studies have been conducted and new
monitoring programs have been added. All of these programs are outlined below.
3.1.1 Water Quality Monitoring –
The City’s monitoring programs have been evolving through annual assessment and incremental
modification. Objectives of water quality monitoring now include evaluating the impacts of urban
stormwater runoff and illicit non-stormwater discharges on water quality; identification of illicit
discharges; assessing the quality of streams within the City of Durham; producing monitoring data
comparable to data collected by the state; estimation of nutrient loads; evaluation of water quality
trends; and assessing compliance with state water quality programs, including TMDLs and nutrient
management strategies. Monitoring data may be used to support illicit discharge investigations,
assess sources, evaluate trends, estimate nutrient loads, and, where possible, gauge the
effectiveness of the Stormwater Management Program (SMP). Special studies are used to
investigate specific questions that may relate to pollutant sources, fate and transport or to
effectiveness of specific SCMs (BMPs).
In order to meet these objectives the City of Durham conducts two different types of monitoring
programs, those that generate water quality information for later use and analysis, and those that
generate water quality information for immediate use. Programs that generate water quality
information and data for later use and analysis are generally structured to evaluate some long-term
condition, such as the evaluation of trends or effectiveness of specific SCMs, as described above.
These programs involve visiting streams throughout the city to collect samples on a regular basis or
installing measurement devices that can record conditions continuously for later retrieval. Generally,
water quality monitoring refers to these traditional monitoring schemes.
Other programs generate water quality information for immediate use. Investigations of discharges
to the stormwater conveyance may result in the collection of water quality information and data, as
will the regular inspection of stormwater outfalls. Illicit discharge and improper disposal programs
are reactive programs designed to find illicit (and illegal) discharges of pollutants to the city
stormwater conveyance system. These programs generate water quality information and data
selectively and quickly for the purposes of identifying and eliminating the pollution source.
The two types of monitoring, traditional and illicit discharge, are not mutually exclusive. Traditional
monitoring may indicate the presence of an illicit discharge that staff then attempt to locate. For
example, if bacteria concentrations from traditional monitoring are significantly elevated, the
laboratory conveys these results within 24 hours so that staff can attempt to locate the illicit
discharge.
3.1.1.1 Traditional monitoring programs
Traditional water quality and quantity monitoring in the city is comprehensive and includes a variety
of types of measurements. Short descriptions of the monitoring programs are provided in Table 3-1.
3-42

Traditional monitoring programs in the city have evolved as needs and permit requirements have
changed. Monitoring began with fixed-interval water quality sample collection in the early 1990s. As
the state and federal water quality programs evolved, and permits were modified, additional
monitoring was needed to track progress toward reducing pollution in city streams and downstream
reservoirs. As shown in Table 3-1, biological monitoring was added to the program in 1999 and fixed
interval water quality monitoring was modified in 2004 to accommodate these needs. Significant
changes occurred in 2008 following an audit of the program.

Table 3-1. Traditional monitoring programs
Type of monitoring Duration Description
Stream monitoring
Water Quality
(Fixed interval)
Quarterly
collection began
in 1991.
Monthly began in
2004
Monthly collection of stream water samples from
fixed locations throughout the city. Samples are
analyzed for a variety of water chemistry
parameters, including conventional pollutants and
metals.
Biological Since 1999 Annual collection of benthic macroinvertebrates
from fixed stream locations throughout the city.
Samples are analyzed for species diversity and
pollution tolerance.
Stream Discharge Since 2008 Continuous collection of stream discharge and/or
stage from fixed locations. A significant portion of
discharge monitoring is accomplished through the
US Geological Survey.
Pseudo-instantaneous measurements of stream
discharge are also collected in streams throughout
the city.
Meteorological
monitoring
Since 2008.
Monitoring at City
Hall since 2000
Continuous collection of a variety of weather related
parameters, with a focus on rainfall. A significant
portion of rainfall monitoring is accomplished
through the US Geological Survey.
Special Studies Since 2008 Short-term continuous, wet weather, or SCM studies
conducted to evaluate specific conditions or
outcomes. These may include water quality, biology,
and/or discharge monitoring.

The Water Quality Unit in the Stormwater and GIS Services Division reevaluates the monitoring
program annually, generally at the end of the calendar year. Water quality and biology monitoring
sites are reviewed to determine if any sites need to be added or eliminated. In order to support illicit
discharge identification and elimination, the City may drop sites that do not have significant water
quality issues in order to evaluate conditions in other streams, or may monitor selected sites one
year out of two, alternating years. Stream discharge and meteorological monitoring are reviewed
less frequently (e.g., every five to ten years) since the deployment of equipment requires a long-term
commitment to those sites.
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Once the City collects and evaluates water quality conditions, it shares them with the public and with
City Management. Because water quality parameters can seem overly technical and confusing, the
City developed its own urban Water Quality Index (WQI) in 2004 to summarize water quality
conditions for physical, bacteriological, and chemical parameters. The index has been used to
evaluate the data collected after 2004 (the year when the City implemented consistent monthly
monitoring and added quality assurance samples). The WQI incorporates the results of monthly
monitoring of pH, turbidity, dissolved oxygen, biochemical oxygen demand, fecal coliform bacteria,
copper and zinc.
An annual average WQI for each site is used as a basis for summarizing water quality conditions in
the city’s annual State of Our Streams reports to citizens.
City Management became interested is using the WQI to track progress more frequently. However,
some of the parameters used in computing the index vary significantly with water temperature,
leading to significant variations from winter to summer. Management asked if it was possible to
remove the seasonal influence so that the index could be used in a monthly reporting to track
changes in water quality. In 2012, the City began computing monthly WQI as a rolling twelve month
average in order to remove normal seasonal variability.
In addition to the State of Our Streams annual report to citizens, and monthly reporting of the WQI to
management, the City annually conducts technical assessment of water quality for internal use and
regulatory reporting. Work products include an annual Water Quality Assessment and Monitoring
Plan, a one-page table that statistically summarizes water quality compliance, and watershed
specific-analysis included in the Water Quality Recovery Plans.
Special studies are designed and executed to answer specific questions about water quality
conditions such as the functionality of SCMs. These studies are generally short-term, less than two
years in duration. Priorities for special studies vary year-to-year. The decisions about which special
studies to undertake depend upon resources available, effectiveness of existing programs, changes
to state rules or procedures, and changes to federal rules or procedures. Examples of studies that
have been undertaken in the past are as follows:
• Wet weather stormwater quality monitoring. Monitoring and evaluation to characterize
stormwater runoff was initiated in 1993. Consultants selected seven sites with relatively
small drainage catchments and collected samples. These sites represented a range of
land uses including industrial; commercial; and low, medium, and high density residential
development. City staff completed the monitoring for this study in 1999.
• On-Site wastewater treatment and disposal study. In 1999 and 2000 the City sampled
effluent from septic sand filter systems. These systems treat residential sewage using a
conventional septic tank combined with filtration through 18 inches of sand and dispose
of any treated effluent that does not percolate into the Triassic clays soils of the area by
discharging to surface drainage. A follow-up study was conducted in 2007 and 2008
showing that many systems had been eliminated but that effluent from the remaining
systems had declined.7
• Bacteria Source Tracking. In 2004 City staff collected 62 samples of scat from domestic
animals, wildlife, and human sources in the Northeast Creek watershed to support a
state-led bacteria source tracking project. City staff also collected 22 stream samples
under both base flow and storm flow conditions at two locations. Consultants tested
bacteria in each sample for resistance to a range of antibiotics, and determined that the
remaining sources were primarily pets and wildlife

7 Woolfolk, et. al. 2008.
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• Northeast Creek Metals Study. The field component of the Northeast Creek Metals Study
was completed in April 2011. A final report was completed in August 2011. The purpose
of this study was to provide supplemental aqueous and sediment metals and sediment
polycyclic aromatic hydrocarbons (PAH) data to support the development of the
Northeast Creek Watershed Management Plan. Results of this study indicated aqueous
cadmium, nickel, and zinc were not a problem in Northeast Creek, although zinc is listed
as a contaminant of concern on the state list of impaired waters (303(d) list). This study
confirmed the inclusion of copper on the state’s list of impaired waters and supports the
evaluation of copper removal in the watershed implementation plan. One PAH evaluated
during this study, dibenzo(a,h)anthracene, exceeded toxicity benchmarks twice and may
need to be addressed in the watershed implementation plan.
• Eno River Study – In 2013 and 2014, the City staff conducted monitoring at seven sites
within the Eno River watershed, 3 on the main stem and four on tributaries. Monitoring
included fixed‐interval water chemistry, instantaneous flow, and sediment chemistry
monitoring, which were all performed on the same day, plus storm event water chemistry
sampling, performed with automated sampling equipment. Parameters included metals
and organics that are not routinely monitored in the City’s existing ambient monitoring
program. Aqueous metals were not reported at toxic levels at any location in the
watershed. Warren Creek had sediment chromium and sediment polycyclic aromatic
hydrocarbons (PAHs) at concentrations that may be toxic to some aquatic species.
Sediment PAHs were often non‐detect or at low concentrations at all other monitoring
locations. Crooked Run Creek had signs of sewage inputs, as evidenced by elevated
nutrients and biochemical oxygen demand (BOD) concentrations. The highest total
nitrogen concentration of the study, 5.6 mg/L, was measured in a storm water composite
sample from Trib 3, the smallest stream monitored during the study, with the majority of
its drainage area located outside the City, and including an older residential development
and a golf course.
A list of past special studies is included in Section 3.1.1.7.
3.1.1.2 Illicit Discharge and Improper Disposal –
The City of Durham uses multiple strategies to address illicit discharges and improper disposal.
These strategies include publicizing a pollution reporting hotline, investigations of concerns
presented by city residents and public employees, screening of dry weather flows at major outfalls
for illicit discharges, tracing and eliminating the source of contaminated flows, promotion of a
household hazardous waste collection center, curb-side solid waste and recycling pick-up, promotion
of recycling of used motor oil, coordination with city and county departments on sanitary sewage,
public education on the hazards of illicit discharges and improper disposal, spill response program,
and progressive enforcement under the City’s Stormwater Pollution Control Ordinance.
The City operates a number of ancillary programs that support this effort.
A comprehensive surface water monitoring program that measures stream flow, chemical, physical,
and bacteriological parameters is used to identify problem areas. A biological assessment program
using benthic organisms also identifies areas most likely to be subject to illicit discharges and
improper disposal. The City has developed and continues to enhance GIS mapping of stormwater
and surface water conveyance, impervious surfaces, land cover, NPDES permittees, industrial
facilities, land use, water distribution system, wastewater collection system, and other mapping
resources that facilitate tracking pollution sources and impacts. Adopt-A-Stream stream watch
programs increase reporting from the community. New storm drains have anti-dumping messages
casted into the iron, while Storm Drain Marker programs place messages on older storm drains to
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increase awareness. The City also periodically conducts special studies to evaluate sources,
transport, and/or fate of pollutants.
The City began focusing more heavily on illicit discharges after a comparative analysis (box and
whisker distributions) of data from stream monitoring and from wet weather land use
characterization indicated that fecal indicators were higher in certain streams than could be
explained by contaminants being picked up by stormwater runoff. EPA guidance documents cite
research indicating that, for some pollutants, dry weather illicit discharges contribute a greater
pollutant load than wet weather discharges.
Inspection of major outfalls and screening of dry weather flows for contaminants (hereafter referred
to as outfall screening) is an important strategy used by the City to identify and eliminate illicit
discharges.
Outfall screening was initiated in 1991 by hiring consultants to inspect major stormwater outfalls
and test dry weather flows for the presence of indicator pollutants. The consultants used USGS
topographic maps to evaluate drainage, identify appropriate catchment sizes, and discharge points.
Field work followed to inspect the condition of the mapped major outfalls under dry weather
conditions. When dry weather flows were found, analytical field tests were performed to screen for
indicator pollutants. The consultants screened 344 major outfalls as part of the process of applying
for the initial NPDES Phase I permit.
Once the permit was issued and a stormwater utility was implemented the City hired staff to continue
and expand various programs. Beginning in FY97, City staff inspected the major outfalls identified
by the consultants and identified additional outfalls to screen. Over 960 outfalls inspections were
completed under dry weather conditions.
Regulatory guidance called for outfall inspection and screening to include assessing odor and visual
indicators of contamination, and screening of dry weather flows for pollution indicators including
chlorine, copper, surfactants (MBAS), and phenols.
Soon after City staff assumed responsibility for illicit discharge detection, ammonia was added to the
screening indicators in order to find sources of inadequately treated sewage. Sewage has been the
most common source of contamination encountered by the City’s stormwater program. Ammonia
has been the best single screening indicator to identify illicit discharges. Illicit discharges tend to be
more frequent in areas of much older development resulting from a combination of aging
infrastructure, inadequate capacity for changed conditions, less protective design practices, poorer
materials and little or no inspection and oversight of construction. More recent guidance by EPA on
Illicit discharges echoes these findings and also recommends the use of ammonia as a screening
parameter.
The City has pilot-tested several alternative indicators of illicit discharges including potassium,
phosphate, and optical brighteners (using a prototype hand-held fluorometer.) The City has also
evaluated alternatives to outfall inspection and screening.
The City conducted short-term, intensive monitoring programs that focused specifically on fecal
coliform bacteria. Because the concentration tends to follow a log-normal distribution, single
measurements are not reliable in identifying hotspots. In areas where illicit discharges were
suspected, 6 to 12 samples were collected at closely spaced sampling sites over a period of weeks
to characterize the spatial distribution of fecal coliform bacteria. In areas of older development with
open channel drainage that is easily accessible for sample collection, this method has been
successful at localizing hotspots, making it much easier to identify or isolate sources that are
intermittent.
When a contaminated flow is found, an investigation is conducted to locate the source so that it can
be eliminated. Initially this typically involved tracing the pipe up-stream until the source of
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contamination is located. In many cases, this process may identify a fairly small area of origin,
where dye testing can be used to identify or confirm a source.
Completion of a project to map the City’s stormwater infrastructure system provided new tools to
facilitate source identification. Initially, GIS maps were accessed using desktop computers. Over
time, various technologies have been used to make GIS data available to investigations staff in the
field. For example, outfall screening teams have used Trimble handheld GPS units equipped with
ArcPad software, followed by tablet PCs equipped with the full ArcGIS application, then by tablets
running a custom GIS application for outfall screening. A database initially developed in 2001 to
track IDDE investigations was replaced in 2015 by a newly designed database with enhancements
including a build-in map and custom reporting tools.
Since 1997 the City has operated a pollution reporting hotline (560-SWIM), which it has promoted
regularly through the City’s stormwater education and outreach program. The City has also made
efforts to train its employees about stormwater, the NPDES permit, the MS4, and the hotline. A
training module on stormwater pollution prevention and reporting is included in the City’s New
Employee Training that is mandatory for all new staff. Increased awareness of both residents and
City employees has resulted in increased calls and investigations.
In addition to programs to find and eliminate illicit discharges, the City implements proactive
programs to properly store, manage and dispose of materials that could become pollutants. The City
operates curbside pick-up for residential solid waste, white goods and recyclables. The City also
operates a Household Hazardous Waste collection center that accepts used motor oil. The City has
also conducted events where city residents can dispose of electronics (E-Wastes) and sensitive
papers (shredding events.)
The City’s Stormwater Pollution Control Ordinance requires auto parts stored outside to be covered,
and automotive fluids and hazardous materials stored outside to have both covering and secondary
containment.
Other strategies to detect and eliminate illegal discharges include:
• Dry-weather inspection/screening to detect contaminated flows;
• Maintenance of GIS mapping of the stormwater, surface water conveyance, and other data to
facilitate tracking of pollution sources;
• Field use of tablet PCs and mapping GPS units to facilitate investigations;
• Maintenance of a comprehensive chemical, physical, bacteriological, and biological monitoring
program;
• Regular visits to monitoring sites;
• Routine evaluation of ambient water quality data to trigger investigations and to help target
outfall screening;
• Use of WQI and fecal coliform bacteria concentrations to target problem areas and changing
conditions;
• Same-day laboratory alerts for fecal coliform bacteria samples exceeding action levels;
• Promotion of a pollution reporting hotline;
• Education of, and reporting by, City inspectors and other employees;
• Responding to citizen requests for service concerning water quality problems;
• Administration and enforcement of the City’s Stormwater Pollution Control Ordinance;
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• Reporting by citizen Stream Watch groups;
• Use of public participation efforts such as Stream Cleanups, Adopt-A-Stream, and Storm Drain
Marker Programs;
• Coordinating with City Water and Sewer Maintenance to capture water contaminated by sewer
overflows and pump it back into the collection system; and
• Special studies to evaluate sources, transport, and fate of pollutants.
To support the IDDE program and to meet other needs, the City revised its Stormwater Pollution
Control Ordinance in November of 2006 to clarify allowable and prohibited discharges. The
ordinance prohibits non-stormwater discharges to the drainage system, with a limited number of
specific exceptions for certain discharges that do not significantly impact water quality, consistent
with Part 1, 9(a) and 9(b) of the City’s NPDES permit, NCS000249. In addition to prohibiting non-
stormwater discharges, the ordinance also requires certain preventative measures like secondary
containment, requires timely clean-up of spills, and provides for escalated enforcement when
necessary to achieve compliance.8 The ordinance was renumbered in 2008 as part of a
reorganization of the entire City code; a copy of the current ordinance is provided in Appendix A.
Facilities that have violated the ordinance may be required to develop and implement stormwater
pollution prevention plans. The ordinance contains many options for achieving compliance. Thus
far, the City has begun assessing civil penalties where necessary to achieve compliance. Under state
law, civil penalties that are part of an ordinance containing criminal sanctions must be turned over to
the school system.
Currently, the City of Durham has a very active Illicit Discharge Detection and Elimination (IDDE)
program that includes a pollution reporting hotline, citizen complaint response, stream monitoring-
response investigations, and education of new City employees. As of the end of September 2016,
the City had conducted more than 4,230 initial investigations, and 3,235 follow-up investigations.
The program employs a wide range of strategies to find and eliminate non-stormwater discharges
that are pollutant sources. Stormwater Services personnel have executed an agreement with NC
Division of Motor Vehicles to obtain vehicle owner information based on vehicle license plate
information for water quality investigations. In conducting investigations, staff members may work
with personnel from many other agencies including NCDEQ’s Division of Water Resources, Division of
Waste Management, and Division of Energy, Minerals, and Land Resources, Land Quality Section;
Durham County Engineering Department’s Stormwater and Erosion Control Division and Utility
Division; Durham County Emergency Management; and Durham County Health Department,
Environmental Health Division. City agencies include Solid Waste Management, Durham Housing
Authority, Department of Water Management, Sewer Maintenance and Industrial Waste
Coordinator/FOG (pretreatment); Zoning Enforcement; Inspections; and Neighborhood Improvement
Services. The City Attorney’s Office is typically involved in enforcement cases where the defendant
elects to bring an attorney to enforcement meetings.
3.1.1.3 Inter-Departmental Coordination –
Over many years, the Water Quality Unit has provided technical assistance and guidance to the City’s
Water and Sewer Maintenance Division when a Sanitary Sewer Overflow (SSO) occurs. This role
became formalized when the Water and Sewer Maintenance Division and Water Quality Unit
coordinated a policy to improve communication on the location of discharges. This policy states that

8 The ordinance also requires specific pollution prevention practices for automotive service facilities. It requires
implementation of a stormwater pollution prevention plan for facilities with a significant number of junk or inoperable
cars.
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when Water Quality Unit staff identify a sewage discharge they will remain on-site to direct a Water
and Sewer Maintenance supervisor to the location.
By 2001, this cooperation had led to many improvements including reducing response times and
setting up pumps and check dams downstream where possible (these contain, collect, and return
sewage to the collection system). In 2003 a further improvement was implemented when Water
Quality Unit staff began providing technical assistance in identifying the extent of contamination
using field analytical kits to detect ammonia and detergents as indicators of sewage (previously
Water and Sewer Maintenance supervisors used visual observation).
Procedures developed by the City for discharges from the City owned collection system have
subsequently been applied in enforcement and mitigation for sewage discharges from private sewer
laterals, pump stations, and systems.
Figure 3-1 shows sewage-related discharges for the period 2013 through March 2019.
Approximately half of these investigations involved discharges from private service lines, discharge
of commercial wash waters, failing septic systems, discharging sand filter systems, failure of
pumping station serving businesses, and other private discharge of wastewaters. Areas of much
older development tend to have more frequent discharges, as indicated by higher density of points
on the map. In these areas, aging public and private infrastructure requires repair more frequently.
Outfall screening in these areas may be effective at guiding repair and maintenance efforts.

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3.1.1.4 Special Studies
The City of Durham conducts special studies to assess water quality in urban streams, to evaluate
trends, to characterize pollution sources, to assess performance of pollution control measures and
to establish pollution reduction credits, enhance understanding of impacted urban streams. In-house
and contractor conducted studies have included:
• Wet Weather Stormwater Quality (1993-1999) to characterize runoff quality and
establish Event Mean Concentrations for stormwater pollutants for a range of land uses.
• Bacterial Source Tracking Study (2004) used antibiotic resistance characteristics of more
than 60 samples of scat collected from the Northeast Creek watershed from domestic
animals, wildlife, and sources to build a library which was used to compare to bacteria
from Northeast Creek stream samples to identify bacteria sources.
• Residential Onsite Wastewater Disposal (1999-2000, 2007-2007) to characterize
surface discharges from single-pass sand filter systems and from failing conventional
septic systems, with follow-up monitoring to assess changes in effluent quality over
time.9
• Ambient Sediment Study (2009-2010) to assess baseline bacteria in urban stream
sediments.
• Bacteria Attenuation Study (2009-2010) to assess the effectiveness of efforts to
remediate sewage discharges that have entered urban streams, and monitor the
duration that bacteria levels in stream sediments remain elevated.
• Sand Filter Demonstration Project (2010-2011) to evaluate the effectiveness of an
alternative treatment process to replace a poorly functioning residential single-pass sand
filter.
• Atmospheric Deposition Study (2009 to 2011) to measure wet and dry deposition of
organic and inorganic nitrogen
• Rain Catchers Project (2011 to present) to assess collective benefit of more than 200
LID retrofit practices in a small catchment in South Ellerbe Creek.
• Aqualutions Feasibility Study and Algae Turf Scrubber Feasibility Study (2012 to 2013)
two concurrent studies to evaluate the feasibility of innovative and alternative measures
to remove nutrients in order to meet nutrient reduction goals.
• Algae Turf Scrubber Pilot Study (2015 to 2017) to install and assess actual performance
of a pilot Algae Turf Scrubber for removing nutrients and sediment.
• Industrial BMP Monitoring Study (2013 to present) to assess pollution removal
performance of BMPs at industrial sites.
• Mobile Car Wash Study (2011 to 2012) to evaluate pollution loads from mobile
commercial car washing operations, and to assist in developing credits for proper
disposal.
• Nitrogen-hydrogen Isotope Pilot Study (2014) to identify sources of nitrogen at the
locations (Third Fork Creek, Ellerbe Creek, and Cabin Branch Creek.)

9 Woolfolk, et. al. 2008.
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• Air Conditioner Coil Cleaning Study (2014-2016) to evaluate pollution loads from several
processes used to restore heat exchange and energy efficiency by removing debris and
corrosion from air conditioner coils and heat exchange surfaces.
The City has significantly expanded its efforts to protect water quality. From the discussion of the
water quality monitoring program components in the previous paragraphs, it is evident that this
program has expanded significantly in scope and type of monitoring, in the number of sites and
watersheds monitored, and in the frequency of sample collection.
3.1.2 Erosion and Sedimentation Control –
Under the 1984 Memorandum of Understanding between the City and County (also discussed in
3.1.3 below), Durham County developed and implemented a Sedimentation and Erosion Control
Program that created the County Sedimentation Control Office (under the County Engineering
Department). Minimum requirements for this locally delegated program were established by the
state’s Sediment and Erosion Control Law. A model ordinance and design manual have been
developed and periodically updated by the North Carolina Division of Energy, Minerals, and Land
Resources, Land Quality Section. Under the state law, Durham County is authorized to administer
and enforce an erosion and sediment program that covers private development throughout the
county, including within the City of Durham, while the NCDEMLR, Land Quality Section is responsible
for reviewing E&S plans and enforcing requirements on publicly funded projects, projects by entities
with eminent domain authority, and exempt agricultural activities.
North Carolina requires an approved erosion control plan for sites that disturb one or more acres.
Initially this standard was used in Durham. Over time, standards in Durham have been revised and
enhanced. In 2002 local requirements were revised to require permits for sites that disturb 12,000
square feet. Local sedimentation and erosion requirements were again recodified with the adoption
of a City-County Unified Development Ordinance which came into effect on January 1, 2006.
Substantial revisions were adopted in 2009 to implement recommendations of the EEUDO Steering
Committee and additional requirements under SL 2009-486. The threshold for requiring an
engineered ESC plan was reduced from one acre to 20,000 square feet of land disturbance. Ground
cover must be established more quickly, and sediment basins and traps must be designed to
achieve 70% settling efficiency, and be able to handle a 25-year storm without overtopping failure.
Current requirements are provided in Appendix D of the SMP. These include procedural
requirements in Section 3.8 of the UDO, slope protection standards in Section 8.8, Sedimentation
and Erosion Control implementation requirements in 12.10, violations in Section 15.1, and
enforcement and penalties in Section 15.5 of the UDO. Readers may find it easier to use the
“smart” version of the UDO that is accessible from the City’s website; extensive hyperlinks between
sections and to definitions make the online version very accessible.
Current applicability requirements are summarized in Table 3-2 below. Permits are always required
for sites that disturb more than 12,000 square feet and approved plans are always required for sites
greater than 20,000 sq. ft. Permits and plans may be required for sites that disturb less than
12,000 feet on a case-by-case basis when the potential for off-site damage exists.
As indicated in the Site Inspection protocol in Appendix E of the SMP, each active project is field
inspected at least once during each calendar month. Compliance issues, heavy rains, project
size/complexity, and citizen concerns serve to trigger additional inspections. Historically, 10-15% of
projects are inspected multiple times each month. Enforcement options include stop work orders,
revocation of permits, civil penalties of up to $5,000 per violation, criminal penalties, and
remediation of damage.
Table 3-2: Sediment and Erosion Ordinance Application
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Less than 12,000
sq. ft
12,000 square feet
to 20,000 sq. ft.
More than 20,000
sq. ft.
Plan MR MR (R*) R
Permit MR R R
Plan to
District R
Table Key:
MR - May be required when off-site damage is occurring, if the potential for
significant off-site damage exists, or if a parent, subsidiary, and/or other
affiliate of the applicant, has engaged in the activities enumerated in Sec.
3.8.7.
R - Required
R* - Required in Lake Michie/Little River Critical Area (M/LR-A), Lake
Michie/Little River Basin/ Protected Area (M/LR-B), Falls and Jordan Critical
Area (F/J-A) and Eno Critical Area (E-A). (see Figure 3-2 for map.)

As indicated in the Site Inspection protocol in Appendix E of the SMP, each active project is field
inspected at least once during each calendar month. Compliance issues, heavy rains, project
size/complexity, and citizen concerns serve to trigger additional inspections. Historically, 10-15% of
projects are inspected multiple times each month. Enforcement options include stop work orders,
revocation of permits, civil penalties of up to $5,000 per violation, criminal penalties, and
remediation of damage.
3.1.3 Water Supply Watershed Program –
The City has a number of programs related to post-construction protection of water quality. The
oldest is the Water Supply Watershed Protection (WSWS) program. Local WSWS are more stringent
than state minimum requirements and are independently applicable from other development
requirements and stormwater performance standards. Independent applicability means that the
most stringent applicable standard applies.
In 1984, Durham City and Durham County coordinated the development and implementation of a
Water Quality Protection and Sediment and Erosion Control Program. This program was
implemented through a Memorandum of Understanding (MOU) between the two jurisdictions. Under
this agreement, the City operates the water quality protection portion for both jurisdictions; the
County operates the sediment and erosion control program for both jurisdictions.
The initial water quality program was applied to all areas of the state within designated water supply
areas with a focus on industrial uses and treatment of runoff from the one-half inch storm. In 1994
a substantially modified program was implemented; the focus changed to a combination of post-
construction stormwater treatment and impervious cover limits to address the impacts of new
development plus protection of riparian buffers in designated water supply watershed areas. These
requirements were re-codified with the adoption of a City-County Unified Development Ordinance
(UDO) on January 1, 2006. The requirements are now found in the Environmental Protection
Standards Chapter of the UDO, Chapter 8, which is provided in Appendix C. Water Supply Watershed
Overlay Zoning, density limits, and stormwater treatment requirements are in Section 8.7. In 2010,
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separate WSWS buffer standards were consolidated with general riparian buffers in Section 8.5.
Reservoir buffers are in Section 8.6.
There are five major surface water supplies in Durham County. Nearly half the City is covered by
water supply watershed overlay zoning districts. The overlay zoning districts are shown on Figure 3-
2. Table 3-3 summarizes the density thresholds for stormwater treatment, the impervious limits, and
the requirements for protecting riparian buffers. Each water supply source has two zones, an inner
area designated as a critical area (denoted by an “A” in the Overlay Zone identifier) and an outer
area (denoted by a “B” in the identifier). For Falls Lake and Jordan Lake the “A” zone is shown in
dark blue while the “B” zone is shown in aqua.
In Figure 3-2, Lake Michie/Little River Critical Area is designated as M/LR-A; Lake Michie/Little River
Basin/Protected Area as M/LR-B; Falls and Jordan Critical Area as F/J-A; Eno Critical Area as E-A; and
Eno Protected Area as E-B. Table 3-2 below summarizes requirements for these areas.
Within protected areas, certain uses are prohibited and others are controlled through special use
permits. Forested buffers of 250 feet to 1,000 feet are required for the permanent pool of major
reservoirs. Riparian buffer widths that must remain forested in WSWS overlay zones are typically
wider than the minimum required buffer width of 50 feet applicable to each side of perennial and
intermittent streams throughout Durham. As shown in Table 3-3, perennial streams require 150 feet
forested buffers in “A” zones and 100 feet buffers in the outer “B” zones. Intermittent streams are
protected by forested buffers of at least 50 feet.
Low density development with imperious maximums as low as 6 percent is allowed in the “A” zones.
In some watershed areas, higher density is allowed with treatment of stormwater runoff. Impervious
limits are supplemented with minimum lot sizes that vary with between the rural and suburban
development tiers. Treatment must be sized for runoff from one inch of rainfall. It must also be
designed to remove 85% total suspended solids in accordance with the NC BMP Design Guide or
equivalent guide. Continued operation and maintenance of the stormwater treatment devices is
provided through an operation and maintenance agreement and a financial surety instrument
between the property owner and the City.

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Figure 3-2: Water Supply Watershed Overlay for the City of Durham 10

10 The water supply watershed overlays in the legend are further explained in Table 3-2 on the next page.
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Table 3-3: Summary of the Current Water Supply Watershed Requirements
Overlay
Zone
Low Density
Option
Impervious
Surface Limit
High Density Option
Impervious
Surface Limit
(requires treatment
of stormwater runoff)
Perennial
Stream
Buffer
Width
Intermittent
Stream
Buffer
Width
Reservoir
Permanent
Pool
F/J-A
Within one-
half mile of
the normal
pool: 6%
Not permitted in the
Rural Tier
150 feet 100 feet
2501 feet
40%, for all areas not
in the Rural Tier and
with uses as allowed
in Sec. 4.11.4
Between one-
half and one
mile from the
normal pool:
9%
Nonresidential Land
Use Restrictions,
intensities greater
than 25% shall
require a Major
Special Use Permit,
Special Use Permit
F/J-B,
E-B 24% 70% 100 feet
50 feet
(High
Density
Option: 100
feet)
E-A 24% Not permitted 150 feet 50 feet
M/LR-A 6% Not permitted 150 feet 50 feet
M/LR-B 6% Not permitted 150 feet 50 feet
1 On nonresidential uses, the Falls/Jordan buffer width shall extend to 1,000 feet.

3.1.4 UDO Environmental Protection Standards –
In 2001 the City and County adopted an environmental protection ordinance that included what
were, at the time, leading edge protection measures. In 2006 the City and County adopted a Unified
Development Ordinance (UDO) that incorporated these provisions with some slightly modified
requirements.
The Durham City-County Planning Department established the Environmental Enhancements to the
UDO (EEUDO) Steering Committee in 2008 to facilitate evolution of the protection standards based
on current science and policy. The EEUDO Steering Committee has recommended enhancements in
the areas of erosion and sediment controls, buffers, wetlands, and water quality protection. Updated
information is available on the City’s web site.11 Some of these enhancements have been included
in ordinance revisions discussed below.

11 This site is available at: http://www.durhamnc.gov/departments/planning/udo_environmental_enhancements.cfm.
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The Environmental Protection Standards are found in Chapter 8 of the UDO which may be found in
Appendix C of this SMP. Current standards require tree coverage and tree protection, establish
floodplain and flood damage protection standards, Riparian Buffer Protection Standards, Water
Supply Reservoir Buffers (discussed in 3.1.3 above), Steep Slope Protection Standards, wetlands
protections Standards, and Protection Standards for the Durham County Inventory of Important
Natural Areas, Plants, and Wildlife, as modified by more current information from the North Carolina
Heritage Program.
Tree protection requirements were enhanced in 2010. Generally in suburban areas, the UDO
requires tree coverage of 20% to 25% for residential development and 10% to 15% for commercial.
Street tree requirements have been added in other tiers. The City’s tree preservation requirements
and its active urban forestry program have resulting in Durham being designated a “Tree City” for
many years running.
The UDO Environmental Protection Standards require protection of a riparian buffer extending 50
feet from the top of the bank on either side of perennial and intermittent streams. In 2010 riparian
buffer protection requirements were revised to include detailed requirements necessary to comply
with Jordan Lake NSW Strategy buffer rules, and during these revisions WSWS buffer protection
standards were consolidated with general riparian buffers. Procedures and implementation
provisions vary between Jordan and Neuse watersheds. Changes adopted in 2010 include:
• Protection buffering of wetlands that are adjacent to or within 50 feet of surface waters in
the stream buffers;
• Requiring diffuse flow from man-made ditches or conveyances prior to water entering a
stream buffer;
• Revision of the table of allowed uses within stream buffers; and
• Procedural changes for permitting, exemptions, variances, mitigation, stream
determinations, and enforcement, and
• Apply the ten-foot no-build zone (setback) currently required for stream buffers to wetland
buffers.
The UDO provides that perennial and intermittent streams are present if the feature is shown on
either the most recent version of the soil survey map prepared by the Natural Resources
Conservation Service of the United States Department of Agriculture or the most recent version of
the 1:24,000 scale (7.5 minute) quadrangle topographic maps prepared by the United States
Geologic Survey (USGS). The UDO also allows the City to make a determination that surface waters
are not present based on an onsite determination by qualified personnel consistent with the
provisions of 15A NCAC 02B .0233(3)(a).

The UDO riparian buffer protections continue to exceed minimum state standards in various ways,
such as being wider in WSWS overlay zones, extending riparian buffer protections to wetlands that
are within stream corridors, and providing 25-ft protected buffers around one acre or larger isolated
jurisdictional wetlands when they are not otherwise subject to riparian buffers.
In addition to slope protection standards applicable during grading and construction as part of
Sedimentation and Erosion Control Standards, the Environmental Protection Standards also include
limitations of development of steep slopes that exceed 25% slope and meet other criteria.
Significant changes have been made to UDO Chapter 8, Environmental Protection Standards in
2009 and 2010, requiring updates to Appendix C of the SMP.
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3.1.5 Peak Flow Requirements –
In 1997, the City adopted a stormwater ordinance that requires applicants for land development to
evaluate peak pre-construction and post-construction runoff for 2-year and 10-year rain events. If
peak discharge will increase by more than 10% after construction, the applicant must evaluate
downstream channel and culvert capacity to ensure they are adequate to prevent flooding or
ponding at culvert entrances (ratio of headwater to depth less than or equal to one). If downstream
capacity is inadequate, the applicant has to provide on-site detention to manage peak flows to
predevelopment conditions.
3.1.6 State Nutrient Management Strategies –
The City of Durham is currently subject to three sets of state rules, listed chronologically:
• Neuse River Nutrient Sensitive Water Strategy
• Jordan Lake Nutrient Sensitive Water Strategy
• Falls Lake Nutrient Sensitive Water Strategy
Post-construction loading limits (yield) for the three nutrient management strategies are set at levels
equal to that of undeveloped land minus the reduction required by the NSW Strategy. For the three
strategies, the loading limits are:
NSW Strategy Nitrogen Limit Phosphorous Limit
Neuse River Estuary 3.6 lb-N/acre/year, no limit
Falls Lake 2.2 lb-N/acre/year, 0.3 lb-P/acre/year
Jordan Lake 2.2 lb-N/acre/year, 0.8 lb-P/acre/year
The nutrient reduction goals, schedules, implementation requirements vary between the three sets
of rules or NSW Strategies. The Falls Lake watershed is located within the Neuse River Basin; the
Falls Lake Nutrient Management Strategy’s post-construction requirements replaced those of the
Neuse rules within the Falls Lake watershed. The Falls Lake NSW Strategy did not include separate
buffer rules but left the Neuse buffer rules in place.
The Neuse NSW Strategy was adopted in 1996 to address fish kills in the Neuse River estuary below
New Bern, North Carolina. Neuse rules have been in place the longest, and are fully implemented.
The Neuse NSW strategy includes a stormwater rule requiring public education, illicit discharge
identification and elimination, identification of retrofit opportunities, and limits on post-construction
nitrogen loading for new development. The Neuse stormwater rule applies to specific, listed local
governments in the Neuse watershed.
The Jordan Lake and Falls Lake NSW Strategies became effective in 2009 and 2010, respectively.
The Jordan Lake and Falls Lake NSW rules require large to very large reductions. The rule sections
are complex, requiring local governments to adopt several different types of local ordinances,
providing schedules that allow for capacity building, staged implementation, and re-examination of
needed reductions at milestones.
In 2010 local governments adopted buffer protection ordinances for Jordan Lake that had been
approved by North Carolina. Durham and other local governments have submitted post-construction
ordinances for both Jordan and Falls NSW rules with ordinance adoption and implementation
required in 2012 after state approval. The Jordan and Falls Strategies include requirements that all
local governments in the watershed reduce nutrient loading from existing developed areas. Strategy
requirements are being phased-in to allow local governments to build capacity.
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The City began implementing post-construction limits on nitrogen loading in 2001 under the Neuse
rules. These requirements are implemented through a city ordinance as performance standards,
rather than through the Planning Department’s Unified Development Ordinance.
In 2009 when the City adopted Phase II post-construction requirements under the NPDES
requirements, the Neuse River performance standards for nitrogen were made applicable
throughout the City, including in the Jordan Lake watershed. In 2010 as rulemaking for Jordan Lake
and Falls Lake progressed, the City adopted more stringent nitrogen requirements and added
phosphorous requirements. The 2010 revisions limit average annual nitrogen yield (loading) to 2.2
pounds per acre per year, and phosphorous to 0.5 pounds per acre per year, with the latter midway
between phosphorous limits under the Falls and Jordan NSW Strategies.
The City submits a separate annual report on its Neuse Stormwater Management Plan. That report
is required to summarize public education activities, new development controls, illicit discharge
detection and elimination efforts, and to identify likely retrofit locations.
The Jordan Lake and Falls Lake NSW rules will require submission of several additional annual
reports for state review.
3.1.7 Land Use Planning
Land use planning and land development practices play a critical role in controlling sources of
pollution. Source control is generally accepted to be much more cost-effective and reliable than
treatment. The City of Durham has been very fortunate to be well ahead of many other
municipalities in land use planning. Land development is reviewed by a combined City-County
Planning Department. Zoning and subdivisions ordinances have been updated and combined into a
City-County Unified Development Ordinance (UDO). In addition, the City and County have developed
a long-range Comprehensive Plan to guide where and how private development should occur and
how the City and County should provide public facilities and services to support future growth. There
are also plans for open space and trails.
The City-County UDO uses zoning to direct where various types of development and certain uses may
be located. The UDO uses urban, suburban and rural tiers to provide a general framework for
consistent and appropriate development. The UDO provides for appropriate zoning and design
standards within these areas. For example, zoning for heavy and light industry limits where such
potential sources of pollution may be located. The UDO also designates overlay zoning for downtown
and compact neighborhood areas to guide where development density is encouraged in order to
foster smart growth and facilitate mass transit. The UDO uses water supply watershed overlay zoning
to provide additional protections and limitations to protect sensitive waters.
In addition to zoning restriction, Article 5 of the UDO requires major or minor special use permits that
provide an additional level of review and approval. Special use permits are required for asphalt
plants, concrete plants, hazardous and low-level nuclear disposal and storage facilities, recycling
centers, and other waste related industries. In areas zoned for light industry, special use permits are
required for automobile wrecking, junk, and salvage yards. Special use permits are required for
campgrounds and RV camps, marinas, and many other uses. Article 5 Section 5.3 requires
convenience stores with gas sales; wrecking, junk, and salvage yards; and vehicle service, including
limited uses vehicle service, provide a spill prevention and counter measures plan with the site plan.
The article also requires that vehicle repair, servicing, and maintenance be conducted within an
enclosed structure so that potentially polluting activities would be shielded from rainfall and runoff.
The Environmental Protection Standards in Article 8 of the UDO discussed in 3.1.4 provide additional
protections.
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Other resources that affect land use planning include the Comprehensive Plan 12 and the City’s
engineering standards (contained in the Reference Guide for Development13). The Comprehensive
Plan focuses on the ultimate needs of the community rather than the pressing concerns of today.
Chapter 7 of the Plan focuses on conservation and the environment. The City’s engineering
standards provide additional opportunities to address specific sources. For example, section 7
requires dumpster pads for food service establishments and that all establishments utilizing
compactors have a drain connected to the sanitary sewer (areas beyond the pad must be sloped to
drain away from stormwater inlets).
3.1.8 Sustainability
Durham City and County together created a City-County Sustainability Office to address multiple
sustainability issues through development of policies and plans that promote use of products that
are recycled, recyclable, bio-degradable, non-toxic, and energy efficient, and through development
and promotion of related environmental initiatives.
3.1.9 Threatened and Endangered Species –
There are no waters either in the City of Durham or immediately downstream from the City that have
been designated as critical habitat for aquatic animal species listed as threatened or endangered by
the U.S. Fish and Wildlife Service or the National Marine Fisheries Service under the provisions of the
Endangered Species Act, 16 U.S.C. 153 1-1 544 and subsequent modifications.14

3.2 State Programs
The following sections discuss the state programs that may affect the implementation of the SMP
Plan.
3.2.1 NC Division of Energy, Mineral, and Land Resources, Land Quality Section
As mandated by state law, erosion and sediment control requirements for publicly funded projects
are enforced by the Land Quality Section of the North Carolina Division of Land Resources. This
section reviews and approves erosion and sediment control plans. City Water Quality Unit staff may
conduct independent investigations of such projects and may conduct enforcement when sediment
is entering a city street, storm drain or stream under the City’s illicit discharge ordinance authorities.
3.2.2 NC Division of Energy, Mineral, and Land Resources, NPDES Stormwater Program
Activities regulated by this program include stormwater discharges associated with industrial
activities and construction, as well as municipal stormwater discharges. City Water Quality Unit staff
conduct inspection of regulated and unregulated industrial and light industrial facilities located
within city municipal boundaries.

12 This plan is available online at: http://www.durhamnc.gov/departments/planning/comp_plan/.
13 This guide is available online at: http://www.durhamnc.gov/departments/works/handbook/.
14 While no area within Durham contains critical habitat, there are areas designated as critical habitat in the Flat
River in Durham County and in the Eno River in Orange County. There are also species of concern in these two
water bodies, possibly in areas near or within City limits. There are also sensitive species in upper New Hope
Creek. The City will need to revisit this issue if annexation substantially changes city boundaries.
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3.2.3 NC Division of Water Resources: Neuse Buffers
State regulations protecting riparian buffers on streams and other waters within the Neuse River
Basin are enforced by the North Carolina Division of Water Quality. The City requires development
projects that propose to impact riparian buffers in the Neuse River Basin to provide a letter from the
state authorizing such impacts.
3.2.4 NC Division of Waste Management
The North Carolina Division of Waste Management is responsible for solid waste, groundwater
contamination from leaking underground storage tanks, dry cleaners, Superfund clean ups, etc.
When the City finds contaminated groundwater entering the drainage system, it coordinates with the
staff in the Raleigh Regional Office of the Division of Waste Management.

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4 Permitting Information
4.1 Responsible Party Contact List
The position responsible for the overall implementation of the SMP, including the coordination of all
program activities, is the Assistant Director of Public Works, Stormwater and GIS Services. The
Division of Stormwater and GIS Services was reorganized in FY 2012 to improve coordination and
provide greater accountability. Contact information for the Assistant Director of Public Works,
Stormwater and GIS Services is provided below:

Name: Paul Wiebke, P.E.
Position: Assistant Director of Public Works
Address: City of Durham
101 City Hall Plaza
Durham, NC 27701
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
4.2 Organizational Chart
Organization is discussed in greater detail in Section 7.1. An overall organization chart for the City is
provided in Figure 7-3, while an organization chart for Public Works is presented in Figure 7-4.
The City of Durham’s Storm Water and GIS Services has responsibility for many of the activities
indicated in the SMP Plan. Stormwater and GIS Services is a Division of the City of Durham
Department of Public Works. The Water Quality Manager is responsible for compiling data for annual
reports. This includes obtaining reports from staff on programs and measures, and obtaining data
from various departments, divisions, and work units throughout the city to track and report on
progress to fulfill the measurable goals listed in Section 7.
An example list of key individual contacts is provided in Appendix H. An updated list will be provided
in each annual report.

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4.3 Signing Official
The signing official for the SMP Plan and the annual reports is the Director of the Public Works
Department (the Storm Water Services Division is part of this Department). Contact information is
provided below:

Name: Marvin G. Williams
Position: Director of Public Works
Address: City of Durham
101 City Hall Plaza
Durham, NC 27701
E-mail: [e-mail]

4.4 Duly Authorized Representative

Appendix G provides a copy of the authorizing action taken by the Durham City Council.

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5 Co-Permitting Information (if applicable)
5.1 Co-Permittees
No co-permittees are involved in this SMP Plan.

5.2 Legal Agreements
This section is not applicable to the City of Durham.

5.3 Responsible Parties
This section is not applicable to the City of Durham.

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6 Reliance on Other Government Entity(ies)
6.1 Name of Entity
As indicated in NCS000249, and explicitly acknowledged in the permit and Section 7.5 of this SMP
Plan, construction site runoff within the City of Durham is regulated by three other entities: Durham
County Stormwater and Erosion Control Program (which handles construction projects by entities
that do not have the power of eminent domain such as private projects - most types of construction),
North Carolina Department of Transportation (which handles state road projects), and the North
Carolina Division of Energy, Mineral, and Land Resources, Land Quality (which handles projects by
entities with eminent domain authority or that are publicly funded). See Section 7.5 for further
details.
The City of Durham operates its own Public Education and Outreach Program. The City is also a
founding member of the Clean Water Education Partnership, for which it is the second largest source
of funding, and City stormwater staff members actively participate in selection of themes, messages,
and target markets for mass media education.
The City continually explores ways of leveraging outside resources to enhance our efforts. For
example, the City has contracted with the Ellerbe Creek Watershed Association, a private non-profit
organization, to conduct additional public education and outreach, and to identify and implement
green infrastructure-type stormwater retrofits for existing developed areas. The City may develop
pilot programs with other governmental or non-governmental agencies to meet state goals. As of
2013, the City was not relying on these contracts to meet its obligations under NCS000249.
6.2 Measure Implemented
Measure 7-5 is implemented primarily by Durham County Stormwater and Erosion Control Program,
North Carolina Department of Transportation, and North Carolina Division of Energy, Mineral, and
Land Resources, Land Quality

7-1(e) is implemented through participation in the Clean Water Education Partnership.

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6.3 Contact Information
Durham County Engineering and Environmental Services
Division Manager, Stormwater & Erosion Control Division
Engineering Department
120 E. Parrish Street
Durham, NC 27701
[phone]

North Carolina Department of Transportation
NCDOT
Roadside Environmental Unit
1557 Mail Service Center
Raleigh, NC 27699-1557
[phone]

North Carolina Division of Energy, Mineral, and Land Resources, Land Quality
Sediment Emergencies Call 1-866-STOPMUD
Regional Engineer
1628 Mail Service Center
Raleigh, NC 27699-1626
[phone]

Clean Water Education Partnership (CWEP)
P.O. Box 12276
Research Triangle Park, NC 27709
[e-mail]
[phone]

6.4 Legal Agreements
The Durham County Stormwater and Erosion Control Program originally operated its program within
the City of Durham under an authorizing resolution adopted in 1984. In 2005 the City Council and
County Board of Commissioners adopted a Unified Development Ordinance (UDO) that incorporated
provisions of the County S&E Ordinance. Under the UDO, construction site plan review, site
inspection and enforcement continue to be handled by Durham County Stormwater and Erosion
Control. Applicable sections of the UDO are provided in Appendix D, which will be updated as
changes are adopted.

The agreement establishing the Clean Water Education Partnership is provided in Appendix F.

6.5 Recognition of Contributions
Although the City does not rely on other entities to implement this SMP, the City acknowledges the
time, energy, and hard work of the many watershed and stream watch organizations within its
boundaries. Notably these include the Ellerbe Creek Watershed Association, Eno River Association,
Friends of New Hope Creek, Friends of South Ellerbe Creek as well as the many smaller
neighborhood/stream watch organizations such as the Old North Durham Neighborhood Association
and Friends of Northeast Creek. These organizations conduct numerous projects entirely on their
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own. Many also work with the City on specific projects to conserve sensitive land, restore and
protect water quality, and preserve the City’s natural resources.
The City of Durham also wishes to acknowledge the ongoing work and accomplishments of many
other entities at work within the City. These groups include the Durham County Health Department,
Durham County Engineering, and the other groups listed below.
The City has been pleased to work with the North Carolina Ecosystem Enhancement Program to help
facilitate projects it has undertaken within the City that include stream restoration, buffer
enhancement/restoration, and treatment of stormwater flows from existing development.
The Durham Soil and Water Conservation District has long been active in water quality protection,
initially working to prevent soil loss related to agricultural practices. The District conducts water
quality education programs and for many years has hosted an “Environmental Field Day” at the West
Point on the Eno City Park for fifth graders in Durham County. This event is supported and has
participation from many resource agencies, including the City’s Water Management Department and
Stormwater Services Division. The District also completed one of the first urban stream restoration
demonstration projects in North Carolina on a small section of Goose Creek with very limited funding.
The District continues to conduct valuable programs and projects within Durham, both on its own
and in partnership with the City.
The City has also been privileged to work with researchers and staff at North Carolina Central
University, North Carolina State University, Duke University, and the University of North Carolina in
Chapel Hill. The City has funded research both directly and through participation in the stormwater
section of the NC Urban Water Consortium.
These entities are making significant contributions toward protecting water quality (which is the goal
of the City’s Municipal NPDES permit). They also perform activities in the areas of stream
restoration, public involvement (such as stream clean-ups), and public education. The City may
serve as a grant partner or otherwise support and participate in the work of these entities, but these
groups also undertake work independent of City participation.
As discussed in Section 7, the City is committed to undertaking its own efforts to implement the SMP
and does not intend to rely on entities other than those acknowledged in the permit in Part II (E) and
discussed above and in Section 7. The City expects that annual reports under the NPDES permit and
SMP may include activities performed by other entities and groups in partnership with the City. In
order to provide a more complete picture of efforts to restore and protect water quality within the
City, annual reports may also include information on significant achievements and contributions
made independent of City involvement. Such information is intended to be supplemental.

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7 Stormwater Management Program (SMP) Plan

The goals of this SMP are to:
• Reduce the discharge of pollutants from the
MS4 to the maximum extent practicable;
• Protect water quality; and
• Satisfy the appropriate requirements of the
Clean Water Act-NPDES Program.
This SMP Plan details the proposed program
elements to be implemented under the City’s
NPDES municipal storm water permit,
NCS000249. The City’s permit incorporates the
six minimum control measures now required
under the NPDES Phase II program. It also
includes other provisions applicable to Phase I
programs. This SMP includes the best management practices (BMPs) that will be used to fulfill
requirements, the measurable goals for each BMP, the implementation schedule (and frequency, if
applicable) for each BMP, and the person or positions responsible for implementation.
Annual reports will summarize the City’s progress in
implementing the BMPs in the SMP Plan, provide
interim assessment of the effectiveness of components
of the SMP, and, if necessary, propose adjustments or
changes.
Under federal Phase I stormwater regulations,
municipal permittees are required to assess and
evaluate the effectiveness of their SMP over time and
revise or enhance best management practices until
water quality standards are achieved. This iterative
process, shown in Figure 7-1 15, is sometimes referred
to as adaptive management or continual process
improvement. This process includes the steps of
developing a plan, implementing it, evaluating its
effectiveness, and then repeating the whole process
until the desired water quality goals are met. The City of
Durham’s stormwater program has undergone
considerable evolution and will continue to do so under
the current SMP Plan.

Figure 7-216 shows the many different outcome levels at which effectiveness can be assessed. While
the ultimate goal is to restore and protect water quality in receiving waters, it is recognized that for
many pollutants knowledge regarding sources of the pollutant and how that pollutant moves through
the environment is incomplete. Adaptive management provides the opportunity to begin

15 California Stormwater Quality Association (2007). Municipal Stormwater Program Effectiveness Guide. California: CASQA.
16 Ibid.
Figure 7-2: Classification of Outcome
Levels

Figure 7-1: The Iterative Process of
Stormwater Management

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management based on what we know, recognizing that much more information will be needed in
order to achieve restoration.
Assessing changes and establishing statistical trends in receiving water quality parameters based on
monthly monitoring data is a long-term activity that requires many years of data. The City began
regular monthly ambient water quality monitoring in January 2004. Since monthly monitoring began,
the area has experienced two severe droughts. Such variable climatic conditions may require a
larger than usual dataset in order to assess trends.
In general, outcomes higher on the pyramid in Figure 7.2 require much longer time-horizons for
implementation and assessment. The City has developed the capability of assessing changes in
receiving water quality as discussed in Section 3.1.1 and Section 7.9 of this SMP, and in the annual
Water Quality Monitoring and Assessment; however, the primary focus of assessment under this
SMP will be on levels lower in the pyramid. Compliance with this SMP focuses on Level 1
assessment. Through membership in the Clean Water Education Partnership, the City will evaluate
progress at Level 2 on the pyramid. Progress at Level 3 is documented at the individual site level.
During the term of the permit the City will periodically report on higher outcome levels as information
is available.

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7.1 Program Implementation
This section introduces the general organizational structure of the City, discusses the city and county
departments that play significant roles in carrying out this SMP and summarizes their general
responsibilities, discusses how the stormwater program functions are funded, and introduces
tracking of Stormwater Management Plan Goals and management practices that will be discusses in
subsequent sections.
The City of Durham has developed a Strategic Plan that guides overall management. The activities
undertaken to implement this stormwater management plan support a number of Strategic Plan
Goals. Other departments and work units support the goals that are supported by this SMP. Thus,
the Strategic Plan provides an opportunity to further improve coordination across city departments,
divisions and work units that share similar goals, leading to more efficient and effective effort.
7.1.1 City Organizational Structure
The City operates under a Council-Manager form of government. Budget authority rests with the City
Council which is comprised of seven members. The City has more than 2,600 full-time employee
positions authorized in the FY19 budget. The City provides police and fire protection, water and
sewer services, solid waste collection and recycling, public works, neighborhood improvement
services, transit and parking services, and administrative services. The City also engages in
community development, economic and work force development, and human relation activities.
Planning, building inspections and zoning enforcement are handled by combined City-County
Planning and City-County Inspections Departments. Public Works handles inspection of roads, water
and wastewater utility lines, stormwater conveyances, and stormwater management facilities.
An overall City organizational chart is provided in Figure 7-3 showing the departments and reporting
paths within the City. Annual reports will provide updates on the City’s organizational structure.

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Figure 7-3: City Departments Organization Chart (as of 10/29/2018)

7.1.2 Departments and Positions Responsible for SMP Implementation
NPDES permit NCS000249 includes requirements that apply to and impact many different
departments within City government and require coordination with several departments within
County government. City of Durham departments that contribute to the goals of the SMP include
Public Works, General Services, Water Management, Parks and Recreation, Fire, Technology
Solutions, Solid Waste, and Neighborhood Improvement Services. City and County combined
departments that contribute to the goals of the SMP include the Planning and Inspection
Departments. County departments involved include the Engineering (Stormwater and Erosion
Control), Emergency Management, and Public Health. Each of these groups and the role they play in
implementing the SMP Plan is summarized in the sections below.
Public Works Department
The Public Works Department contains the core functions responsible for managing, operating and
maintain the municipal stormwater system. The Public Works Department is organized under three
Assistant Directors, as shown in Figure 7-4. Annual reports will provide updates regarding the
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stormwater functions within the Public Works Department, together with a table listing contact
names associated with key roles in implementing this SMP. Divisions and work groups within the
Public Works Department are discussed below.

Figure 7-4: Public Works Department Organization (as of 10/29/2018)

Stormwater and GIS Services Division
This division is the lead in coordinating development, implementation and assessment of the
Stormwater Management Plan. Key elements of the plan are carried out by work groups within this
division. There are five work groups within the Stormwater and GIS Services Division:
• Stormwater Infrastructure
• GIS/Stormwater Billing
• Stormwater Development Review
• Water Quality
• Watershed Planning and Implementation
Stormwater Infrastructure Group - Major responsibilities are:
• Drainage Projects - stormwater construction projects within City Rights of Way or on City property
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• Drainage Response – customer assistance with questions about drainage problems on private
property
• Floodplain Response – customer questions about: floodplain information, floodplain building permits,
and the National Flood Insurance Program
GIS & Stormwater Billing – Major responsibilities include:
• Stormwater utility billing and customer service
• Mapping parcel-based impervious surfaces to support billing
• Maintaining GIS inventories of the stormwater, water and sewer systems, as well as street centerlines
(stormwater system base map)
• Technical support for the SCM and 2015 investigations databases
To support stormwater utility billing the work group obtains annual satellite imagery to aid in
maintaining current maps of parcel impervious surface. The work group also uses survey grade GPS
instruments to update inventory data and contracts for outside professional services to support
mapping functions.
Stormwater Development Review - Major responsibilities include:
Conducting seminars for the engineering and development community.
Review of preliminary plats, final plats, site plans and construction drawings for conformance with
engineering design and performance requirements for stormwater conveyance, management and
treatment
• Management of acceptance As-Built certification process for completed stormwater BMPs
• Management of annual stormwater BMP inspection process
• Maintenance of the SCM Tool database of BMPs (under construction and completed)
• Operation of certification programs for As-Built certification and for annual inspection
The Stormwater Development Review work group includes Registered Professional Civil Engineers,
engineering technicians, and administrative staff. Stormwater development review group performs
many other duties including support for watershed planning in the areas of upland assessment, BMP
evaluation and identification of potential retrofit locations.
Water Quality - Major responsibilities of this group include:
• Illicit discharge programs
• Inspection of industrial and light industrial facilities
• Inspection of city facilities and technical support
• Water quality monitoring programs
• Watershed planning support
• TMDL response plans
The work unit maintains the water quality sections of the city’s web page; periodically gives
presentations to the Environmental Affairs Board (EAB, citizen advisory group); inspects private and
city facilities; conducts dry weather outfall screening; investigates concerns from citizens, city
employees, monitoring data; identifies and eliminates sources; conducts enforcement; maintains
databases for monitoring results, inspections and investigations; ambient, benthic and lake
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monitoring; conducts water quality assessments (statistics, trends, load calculations); supports
watershed planning in the areas stream assessment, water quality assessment and modeling;
prepares annual reports; coordinates development of the SMP; coordinates with state regulators and
state resource agencies; implements grant-funded demonstration projects; and contracts for USGS
gaging stations, laboratory services, database maintenance, implementation for grant projects.
Watershed Planning and Implementation – This work group leads the City’s watershed planning and
implementation, implements residential stormwater education and outreach, and coordinates public
participation and involvement. Development of watershed implementation plans requires
coordination across work groups and departments, development of scope of services and
contracting, coordination of data delivery (e.g. GIS data, water quality data,) coordination of city
participation in contractor-lead field activities including stream assessment, upland source
assessment BMP assessment, and identification and evaluation of potential retrofit locations. This
work group also does planning and contracting for retrofit planning, design and construction, and
contracts with outside agencies to support Green Infrastructure implementation, supplemental
workshops, a Facebook page; develops and distributes brochures, flyers, and guidance documents;
conducts targeted mailings; participates in development of the CWEP media campaign; promote the
stormwater hotline; works with contractors to produce educational videos; coordinates a speaker’s
bureau; conducts workshops for educators and homeowners; promotes or coordinates stream
cleanups; and coordinates storm drain markers.
Street Cleaning – This work group is within the Maintenance Operations Division of Public Works
operates a fleet of street sweepers that clean city streets, gutters and inlet grates on stormwater
inlets. In addition, work details pick up trash along city right-of-way, manually clean bus-stops, and
perform dead animal pickup.
Stormwater Maintenance – This work group is within the Maintenance Operations Division of Public
Works maintains roadside ditches, repairs catch basins, uses video inspection equipment to assess
the need to repair or maintain buried pipes and features such as catch basins. When cleaning is
needed, Vactor trucks are used to clean inlets (e.g. catch basins) and associated piping.
Water Management Department
The Water Management Department operates and maintains a water distribution system and a
sanitary sewer collection system, two water treatment plants, and two wastewater treatment plants.
The Water Management Department also operates an industrial pretreatment program to control
discharges of industrial waste into the city collection system.
The Water Management Department implements a water conservation program which offers rain
barrels, shower head replacement, and toilet replacement rebates. When opening hydrants to flush
the water distribution system, the discharged water is passed through a diffuser that contains a
dechlorinating agent.
The two wastewater treatment plants were initially upgraded to provide nutrient removal in the
1980s, and have since been further upgraded to state-of-the art treatment for nutrients. The
collection system serves users throughout the city with the exception of the Northeast Creek basin,
which is served by Durham County. The Water Management Department remediates the impact of
sanitary sewer overflows (SSOs) where possible by capturing the contaminated water and pumping it
back into the collection system. To assure complete capture, the department typically coordinating
with the Public Works Department’s Water Quality Unit for water quality testing to assess the extent
of contamination.
City/County Planning Department
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The City/County Planning Department coordinates development review and implements a Unified
Development Ordinance (UDO)17. A key stormwater provision of the UDO are the requirements that
protect County-wide riparian and wetland buffers, water supply watershed riparian and reservoir
buffers, together with overlay zoning density limits in critical watersheds. Zoning enforcement within
the department ensure compliance with riparian buffers requirements after construction.
Other responsibilities under the UDO are zoning, subdivision, comprehensive planning, and local
area planning. The department manages reviews by the Joint City/County Planning Commission, the
City’s Development Review Board (DRB), the Board of adjustment (BOA), and City Council. In
addition, the department also coordinates the acceptance review process for site plan applications
to ensure completeness before the plans are distributed to Transportation Division, Engineering
Division, Stormwater & GIS Division, and the County Stormwater and Erosion Control program for
review.
Fire Department (Spill Response Program)
The Fire Department has a HAZMAT (HAZardous MATerials) Team that assists with containment of
spills. The Fire Prevention Bureau supervised by the Fire Marshall inspects all commercial buildings,
including industrial sites, regarding materials storage and fire safety.
Technology Solutions Department
The Technology Solutions Department manages computer systems, servers, and networks. Their
duties include maintaining computer network and associated servers, Geographic Information
System (GIS), enterprise databases, and various other databases. (Note that staff with the
Stormwater and GIS Services Division develop and maintain various databases and stormwater-
related geodatabases that support stormwater management.)
City Attorney’s Office
The City Attorney’s Office handles stormwater- related legal matters, including permit review, assistance
with ordinance development, support of enforcement efforts, and review of contracts and
agreements.
Solid Waste Department
The Solid Waste Department provides curbside solid waste, curbside recycling collection and fee-for-
service curbside yard waste collection to residential customers. The department also provides
collection services to businesses and residents in the downtown area at designated pickup
locations. In 2008, the department began providing free bulky item and white goods collection. The
department provides support for City-sponsored stream clean ups in the spring and fall, as well as
year-round support for Adopt-A-Stream and Adopt-A-Street programs. A Solid Waste code
enforcement officer handles solid waste containers placed in the right-of-way for collection. The
department also operates the City’s Household Hazardous Waste Collection Center, open five days
per week and funded in part by the stormwater utility; much of the hazardous material collected is
recycled. The department also operates a Convenience Center for drop off of materials that may be
reused or recycled.
Neighborhood Improvement Services
Neighborhood Improvement Services (NIS) handles enforcement of ordinance code pertaining to litter,
junk and debris, weedy lots, graffiti, abandoned vehicles and carts, as well as minimum housing
requirements. NIS addresses illegal set-outs and illegal dumping related to rental housing. NIS also
sponsors and leads Landlord Training Workshops for property owners and property management
companies; workshops ore typically offered once or twice per year, and include presentation modules

17 This is also discussed in Section 3.1.2-3.1.4.
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by Stormwater and Water Management on property owner/manager responsibilities regarding response
to sewage discharges and responsibility for tenant activities that result in stormwater pollution.
Durham County Stormwater and Erosion Control
This group is part of the Durham County Engineering Department. It administers a locally delegated
program under the City/County Unified Development Ordinance adopted by both City Council and
Durham County Commissioners.18 Responsibilities of the group include reviewing local construction
erosion and sedimentation control plans, issuing land disturbance permits, and conducting regular
monthly inspection of construction sites.
General Services Department
The General Services Department is responsible for project design; property acquisition;
construction; contract bidding; construction contract administration; inspections of most city
construction projects including buildings, parks, and trails (exceptions are public works, construction
at treatment plants and solid waste transfer facilities, and utilities projects related to water system,
sewer system, sidewalks and streets). General Services is also responsible for street trees and for
maintenance of landscaping and right-of-way. Tracking associated with the City Sustainability Plan is
also performed by General Services.
Environmental Education and Public Involvement
The City has staff and funding dedicated to educating businesses and the general public about the
impacts of stormwater runoff. These efforts are complemented or supplemented by efforts
undertaken by other agencies that play an important role.
Parks and Recreation Department
The Parks and Recreation Department maintains park trails and greenways. The group also operates
programs at City parks and trails (including two dog parks). This group has partnered with the
Stormwater Services Division to operate pet waste stations in parks and along trails.
City/County Sustainability Office
www.greenerdurham.net. This department works with city and county employees to improve how
government does business and promote environmentally responsible leadership. The Sustainability
Office also works with people and organizations in the community to enhance sustainable living
through public education, sponsored events, and other outreach as needed, such as Trees Across
Durham. The Sustainability Office implements Durham’s Greenhouse Gas Emissions Reduction Plan.
Keep Durham Beautiful, Inc.
This is an independent non-profit funded by the City and County that addresses litter prevention,
waste reduction and beautification. Keep Durham Beautiful engages volunteers, leads stream
cleanups and adopt-a-street programs, and promotes Trees Across Durham.
Durham County Soil and Water Conservation District.
The Soil and Water Conservation District is guided by an elected board, and implements programs to
assist farmers, and to reduce soil loss and manage nutrients in agricultural practices. The District
has a stormwater specialist, operates environmental education programs, and operates a cost share
program to implement stormwater retrofit practices on residential property.
Field Services

18 This is discussed at length in Section 3.1.3.
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The Water Quality Unit within the Public Works Department coordinates frequently with a number of
city and county departments that may encounter illicit discharges in the course of doing other work.
City/County Inspection Department
This department is responsible for building permits and inspections. It also takes care of zoning
inspection and enforcement. Zoning enforcement staff members coordinate with the Water Quality
Unit on pollution prevention at automotive service facilities.
Durham City-County Emergency Management
This is a county line department operated with funding from the city and county. The department is
responsible for county emergency planning and response, including handling chemical spills
(including coordinating spill response, clean up, and reporting). Department staff coordinate and
support the Durham Local Emergency Planning Committee (LEPC), a group of concerned individuals
from different local agencies and businesses within Durham County who work together to assure
that our community has the emergency planning and response capabilities to effectively prevent, or
mitigate, emergencies and disasters. Examples of issue that are significant for stormwater
management include development of a comprehensive and details list of the capabilities of
environmental cleanup companies operating in Durham County, and coordination on hazards of
discharges from industrial accidents.
Durham County Utility Division
Durham County operates the Triangle Wastewater Treatment Plant and a sanitary sewer system that
serves Research Triangle Park, which is an unincorporated area outside city limits. However, the
collection system extends beyond the boundaries of Research Triangle Park serving much of
Northeast Creek, including areas within the City of Durham. The division typically coordinates with
the Water Quality Unit in the City of Durham’s Public Works Department when there is a major
sanitary sewer overflow within the City.
Durham County Environmental Health Division
The Environmental Health Division promotes and protects public health through mandated
inspections and the enforcement of local and state public health laws, rules and regulations. The
Division inspects restaurants and other food service facilities, as well as permitting and inspecting
septic systems. The division often coordinates with the City of Durham Stormwater Services Division
to resolve violations involving improper grease handling.
7.1.3 Funding
Funding for the City’s stormwater program is provided through a stormwater utility. Utility fees are
based on the amount of impervious surface on a property. This is true of both residential19 and non-
residential development. Miscellaneous revenues are derived from review fees for land
development projects that require stormwater management facilities. The City’s annual NPDES
reports include revenues and expenditures for the Stormwater Utility, positions funded by the utility,
and budget for the approved Stormwater Capital Improvement Program, and information on any
changes in utility rates.
Within Stormwater and GIS Services, budget needs are managed and coordinated by the Assistant
Public Works Director of Stormwater & GIS Services based on input from the work groups within the
division. The Assistant Public Works Director of Stormwater & GIS compiles the needs and initiatives
from all the groups across the Public Works Department and then works with its director to develop

19 Fees for residential development are divided into three tiers. The lower tier is for those residential units with less
than 2,000 square feet of impervious surface; all other residences with more impervious areas are assigned to the
second or third tier.
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the overall budget request for the Public Works Department. This budget then is sent to the City
Manager’s Office and the City Council for further approvals.
7.1.4 Tracking SMP Plan Goals
The Public Works Department’s Water Quality Unit department tracks a wide range of metrics to
assess work load, amount of time devoted to an essential task, as well as outcome indicators
showing efficiency or effectiveness. Most of these indicators are used for internal tracking and
management within the work unit to maintain assess weakness, inform training needs, enhance
accountability and maintain performance.
Many indicators tracked by the Water Quality unit are also used to track progress toward meeting the
goals this Stormwater Management Plan. The Water Quality Unit has developed a summary guide of
the performance metrics it tracks which includes some examples on how the data is assessed. The
summary guide includes examples showing how the data is used. In many cases, the examples are
from annual reports.
Metrics and indicators tracked by the Water Quality unit are also used to assess and report progress
toward meeting departmental work goals and the goals of the City’s Strategic Plan, and thus are not
unique within either the Public Works Department or the city as a whole. The City establishes key
performance indicators for each department as part of the annual budget process, based on the
City’s Strategic Plan Goals, approved departmental initiatives and City Council priorities. Public
Works tracks the key performance indicators assigned to it in the Budget Book as well as other
performance indicators for every division and work unit. Objectives, performance goals, and specific
work initiatives are established at the beginning of each fiscal year, and individuals from each work
group or division are assigned responsibility to update the statistics on a monthly basis. Selected key
metrics are monthly reported to City Management and City Council members to track progress
toward Budget Book goals.
The City’s annual budget includes results for departmental initiatives and key reporting metrics for
every department for the prior year, and establishes the key metrics for the upcoming fiscal year.

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7.2 Public Education and Outreach on Stormwater Impacts
Objectives for Public Involvement and Participation
Permit NCS000249 requires the City to develop and implement a program of public education and
outreach. The permit provides the following objectives (italics indicate supplemental objectives
added by the City:
• Distribute educational materials to the community.
• Conduct public outreach activities, targeting pollution prevention information to specific
audiences.
• Raise public awareness on the causes and impacts of stormwater pollution and encourage
behaviors that will improve water quality.
• Inform the public on steps they can take to reduce or prevent stormwater pollution.

Table 7-1. BMP summary Table for Public Education and Outreach
BMP Description Measurable Goals Responsible
Position
(a) Describe target
pollutants and target
pollutant sources
Target pollutants, sources and audiences are
summarized in Sections 7.2.1 and 7.2.2 of this SMP
Plan, and discussed in Appendix I.
Water Quality
Manager
(b) Describe target
audiences
(c) Informational
Website
The City promotes and maintains the Stormwater
Services Website:
www.durhamnc.gov/stormwater.

Pages maintained
by each work unit.
(Water Quality Unit
pages: Pollution
Prevention
Coordinator)
The City also financially supports, contributes material
to, and promotes the Clean Water Education
Partnership website www.NC-cleanwater.org
Public Education
Coordinator
(d) Distribute Public
Education Materials to
identified user groups
Acquire or develop and distribute public education
materials to identified target groups.
Public Education
Coordinator &
Pollution Prevention
Coordinator
Develop and distribute information to target business
sectors via targeted mailing (one sector per year) and
industry-specific guidance documents.
Pollution Prevention
Coordinator
Educate homeowners about target pollutants and
stormwater issues (through Waterways and topic-specific
handouts).
Public Education
Coordinator
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BMP Description Measurable Goals Responsible
Position
(e) Promote and
Maintain Hotline/Help
line
Distribute promotional giveaways and specialty items
including pens, rubber ducks, rain gauges, etc. with the
Hotline number printed on them. Create and promote short
videos to promote hotline.
Public Education
Coordinator
Maintain a stormwater pollution reporting hotline. (see Section 7.4
IDDE)
(f) Implement a Public
Education and Outreach
Program
Media Campaign: Document campaign impressions for
each type of media like radio and TV (including those
elements implemented locally or through a cooperative
agreement).
Public Education
Coordinator

Develop utility bill inserts about stormwater issues.
(Waterways)
Participate in community events and festivals through a
table-top display.
Maintain a speaker’s bureau that gives presentations to
civic organizations, business and neighborhood groups.
Organize stream cleanups (Creek Week in spring, Big
Sweep in fall)
Provide outreach through informational workshops.
Outreach to classrooms and school groups.
Develop and promote videos to educate the public on
pollutions sources and the city’s effort to reduce
stormwater impacts
Provide outreach through social media.

The City of Durham’s stormwater education and outreach program uses research-based methods to
increase awareness and to promote changes in behavior. Program components are managed by a
Public Education Coordinator and the Pollution Prevention Coordinator, but other staff provide
significant support for speaker’s bureau and community events.
A report to citizens called State of Our Streams (SOS) is produced in part to educate and engage
Durham’s residents about water quality conditions and results from illicit discharge investigations to
citizens, as discussed under Public Participation and Involvement.
The City is a founding member of, and active participant in, the Clean Water Education Partnership
(CWEP), a cooperative effort between local governments and others. CWEP implements campaigns
in several media markets including Durham. The campaigns are intended to increase awareness and
promote changes in behavior. Annual campaigns change from year to year but may include
television, radio and/or cinema pre-show video spots, depending upon the target audience. CWEP
also maintains a website. The City actively participates in the development of CWEP’s annual
campaigns, and also partners with other organizations on stormwater outreach and education.
Experience has shown that a variety of public outreach methods are required to reach the various
audiences involved. Methods used by the City for a given target continue to evolve. Detailed
information about public education and outreach efforts of Stormwater Services is provided in
standard operating procedures, which includes a list of references regarding effective outreach
methods. Table 7-1 summarizes the approaches.
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The target pollutants, their sources, and target audiences of public education and outreach efforts
are further described below. Further information about how these were chosen is available in
Appendix I.
Additional discussion of target pollutants and audiences that may be specific to a particular
watershed will be provided in Section 7.10 Total Maximum Daily Loads (TMDLs) Response Plans.
Updates to these plans are provided as attachments to the City’s Annual reports, and report on
watershed specific outreach. Watershed specific discussion is also provided in the watershed plans
the City is developing or updating.
7.2.1 Target Pollutants
Target pollutants for stormwater education include: fecal coliform bacteria, nitrogen, phosphorus, low
DO, turbidity, copper and zinc. Although hydrologic modification is considered pollution, and not a
pollutant, increased flow is a condition that has been identified as a priority for public education. Zinc
and copper seem to be associated with the following sources: a limited number of industrial sites, AC
coil cleaning, air conditioner blow-down, discharges from fountains, discharges from underground
electrical vaults, and vehicles. The City adds zinc polyphosphate to the potable water supply to inhibit
corrosion. Therefore, potable water leaks, system flushing, and sanitary sewer overflows may introduce
zinc to surface waters. All of these sources will be addressed through business outreach and industrial
monitoring and inspection as well as with state permitting, and illicit discharge monitoring and control.
7.2.2 Pollutant Sources
Target pollutant sources include:
• Illicit Discharges – Illicit discharges both generally and specifically including improper cleaning,
improper storage, and improper disposal of pollutants;
• Sewage – Sewage from private and public components of the gravity sewer collection system that
may include overflows and blockages caused by food wastes and cooking grease from problem
restaurants and from residents of the City;
• Vehicle Maintenance - Petroleum products and automotive fluids from owner-maintenance of
vehicles and from automotive service facilities;
• Construction Sites – Sediment and/or erosion from construction sites;
• Landscape Maintenance and Lawn Care – Landscape maintenance and lawn care including use
of herbicides, insecticides and other pesticides along with improper yard waste disposal; and
• Atmospheric Deposition – Broad efforts to improve air quality, reduce emissions of greenhouse
gasses, and reduce dependence on petroleum will have water quality benefits.
7.2.3 Target Audiences
Based on the identified target pollutants and their sources, the target audience of this program are:
• General Public – The general public may be educated to recognize and report illicit discharges.
The general public has been selected because of the widespread impacts of routine human
activities and the general lack of awareness of the impacts of stormwater runoff.
• Homeowners - Desired behaviors (or behavior changes) from educating this audience include
activities involving lawn maintenance and stormwater runoff.
• Lawn Maintenance –Desired lawn maintenance behaviors include having soil tested before
applying fertilizers, reading instructions on any chemicals (including fertilizers, pesticides, and
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herbicides) before applying them to a lawn or garden, not applying lawn chemicals before it rains,
minimizing fertilizer usage (especially “weed-and-feed” fertilizer), using slow-release organic forms
of nitrogen fertilizer, using a composting lawnmower that can help reduce fertilizer usage, using
integrated pest management rather than broad spectrum pesticides on a regular basis, and
keeping leaves and grass clippings out of the street gutter by properly disposing of or composting
them. It also includes items such as having lawns aerated, encouraging practices that help
establish deep root systems for lawns, and putting in rain gardens (all of which will help
encourage water infiltration).
In addition, homeowners that live next to a stream will be encouraged to not mow stream banks.
We also would like them to establish vegetative buffers and plant trees along stream edges that
will provide shade help anchor soil in stream banks, filter nutrients from shallow groundwater, and
provide a source of leaf packs that will help keep the food chain stabilized in the river or stream.
• Rooftop Runoff – We would like to encourage homeowners to disconnect rooftop drains from the
MS4 by directing them to lawns (which might include rain gardens) or connecting them to larger
rain barrels or cisterns. In addition, homeowners could regularly clean organic debris from their
gutters (this helps keep bacteria and organic matter from entering our streams). Homeowners
can also plant trees that will shade driveways and other paved surfaces that can lead to hot water
flashes with a rain event.
• Other Activities – Homeowners should dispose of grease properly to keep it from entering and
clogging the sanitary sewer system, properly dispose of household hazardous waste, keep lids on
garbage bins tightly closed to keep out animals, wind, and rain that could cause litter or “garbage
juice.”
• Vehicle Owners – Vehicle owners will be encouraged to properly dispose of any wastes from home
maintenance, regularly maintain vehicles so that they don’t leak fluids, and to wash their vehicles
in such a manner that the run-off doesn’t enter storm drains.
• Pet Owners – Should pick up after, and properly dispose of, their pet’s wastes.
Businesses – Target business sectors will include:
• Automotive Maintenance Facilities – With this group we want to advance the proper usage,
storage, and disposal of automotive fluids and other wastes such as tires. We will also educate
this group about their responsibilities regarding spill cleanups and notification of the correct
officials.
• Rental Property Owners and Managers – We hope to leverage this group to educate their tenants
through information distribution. In addition, we will educate property owners and managers about
their responsibilities for repairing and maintaining sewer service lines and remediating sewage
discharges.
• Landscape Professionals – This group can be educated about proper choice and application of
lawn chemicals such as pesticides, herbicides, and fertilizers. This group would also be an ideal
way to help encourage proper vegetative buffers and stream bank maintenance.
• Restaurants – Restaurant employees will be educated about proper grease disposal and other
equipment cleaning procedures.
• HVAC Contractors– HVAC contractors and their state business association will be trained in proper
disposal of wastewater from washing coils, vent cleaning, maintenance of filter units, and
pressure washing.
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• Students/Young People - Some long-held practices, activities and behaviors have been shown to
contribute to water quality degradation. Younger people are less resistant to changing their
behavior and can help initiate such changes in the rest of society.
Not all of the audiences identified above will be addressed each year. However, each audience will be
addressed at least once during the permit period. Furthermore, Stormwater Services intends to be
reactive to new information and to regulatory programs (including state rules, TMDLs, and NSW
management plan requirements) and will review existing programs and initiate new outreach activities
as they are needed.
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7.3 Public Involvement and Participation
Objectives for Public Involvement and Participation
Provide opportunities for the community, including major economic and ethnic groups, to participate
in program development and implementation.
General Approach
The City uses a variety of methods and mechanisms to involve the public and to solicit comments on
projects, initiatives and overall program development. The methods and mechanisms continue to
evolve.
Table 7.2 contains a summary of the BMPs used to involve citizens in the stormwater management
process and involve them in protecting our local water quality. Details on each approach are found in
standard operating procedures.

Table 7-2: BMP Summary Table for the Public Involvement and Participation
BMP Measurable Goals Responsible Position
a) Volunteer
Community
Involvement
Program
Organize/sponsor volunteer stream cleanup campaigns that
promote resident participation such as Creek Week cleanups and
Big Sweep cleanups. Public Education
Coordinator Work with residents to label storm drains.
Sponsor an adopt-a-drain program.
Sponsor adopt-a-street and adopt-a-bus stop programs.
Executive Director,
Keep Durham
Beautiful, Inc.
(b) Establish a
Mechanism for
Public
Involvement
Presentations to the Environmental Affairs Board, typically
including annual Water Quality Monitoring Plan, Water Quality
Recovery Programs, and other topics of interest.
Depends on topic
(generally Water
Quality Manager)
Annual reports and latest SMP have been posted on City web
site; public comments will be solicited annually with revision
cycle.
Water Quality Manager
Public meetings are held to solicit public input on watershed
plans, major construction projects, retrofit plans, ordinance
revisions
Varies by project
(c) Maintain a
Hotline
The City will continue to maintain and promote a stormwater
pollution reporting hotline.
See Table 7.1(e) and
Table 7.4 (e)
(d) Public Review
and Comment
Stormwater Management Plan has been posted to web site
together with solicitation of comments and suggestions from the
public. Revised versions are posted after approval by NCDEQ.
Water Quality Manager
(e) Public
Notice
Comply with State and City public notice requirements for rate
changes; watershed planning; proposed projects that impact
public use, public access or adjacent properties; and similar
activities. Comply with City policy PA-3.
Notify public of other opportunities to participate.
Assistant Public Works
Director, Stormwater &
GIS Services*
* Responsible party listed for stormwater rate and ordinance changes.
The City is preparing a written Public Involvement and Participation Standard Operating Procedures.
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7.3.1 Volunteer Community Involvement Program
In addition to the volunteer activities provided in Table 7-2 (a), the City and County fund Keep
Durham Beautiful, Inc., an independent non-profit that engages volunteers in litter abatement, waste
reduction education and beautification. Keep Durham Beautiful leads stream cleanups and “adopt-a-
“ programs, promotes the City’s dog parks and the Canines for Clean Water social marketing
campaigns, and promotes “greening” such as Trees Across Durham.
Litter oriented adopt-a-programs include adopt-a-stop (bus stop), adopt-a-street, adopt-a-trail, and
adopt-a-park program. KDB also promotes adopt-a-tree (greening) and the City’s adopt-a-stream
program.
Other efforts are undertaken by the City-County Sustainability Office.
7.3.2 Mechanisms for Public Involvement
Environmental Affairs Board - Durham City and County together established the City-County
Environmental Affairs Board (EAB) to provide advice on environmental issues. City and County staff
from several different departments routinely attend these meetings and bring issues to the attention
of the EAB. The Durham Environmental Affairs Board (EAB) consists of eleven members appointed by
the City Council (5 members), Durham County Commissioners (5 members) and Durham County Soil
and Water Conservation Board (1 member). Stormwater staff members attend all meetings to
address issues that may arise.
City Stormwater Services makes several formal presentations each year to update the EAB and to
seek comment, feedback and guidance. Presentations made each year typically include the State of
Our Streams report to citizens, TMDL Recovery Plans, watershed plans, and other issues. For
meetings at which presentations are not scheduled, Stormwater Services rotates staff members
attending.
Citizen’s CIP Committee - In addition to the regular mechanisms for public involved listed in the table
above, a citizen’s CIP Committee annually reviews the City’s draft Capital Improvement Programs,
including the Stormwater CIP, and provides advice to City Council on priorities.
Watershed Improvement Planning - As part of the process of developing Watershed Improvement
Plans, the city and its contractors generally hold a kick-off meeting to alert the community of the
project and the field work that will be undertaken, and to solicit input and community concerns for
consideration in the planning process. Each plan may include different elements. Additional
meetings usually include the priority system for rating potential projects, the results of modeling
scenarios to evaluate alternatives, and final project findings.
Project Planning Public Meetings – The City holds public meetings to solicit public comment on
planned major stormwater construction projects prior to conducting detailed design. Such meetings
are typically held for stream restorations projects by the City or by partners on city property, major
culvert repairs, and major stormwater work in city parks.
Ordinance Development – The City has held several public meetings each time the post-construction
ordinance has been substantially re-written.
Public Hearings - Durham City Council conducts a public hearing to receive public input prior to
adoption of changes to Stormwater Utility Fees, or changes in penalties.
Additional mechanisms to communicate with, and to solicit concerns from, city residents and
businesses include:
• Residents can bring matters before City Council.
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• Partners Against Crime districts, which usually focus on policing, but occasionally address
neighborhood issues.
• Inter-Neighborhood Council, a consortium of neighborhood organizations, typically meets monthly.
Stormwater staff members attend these meeting upon request, or when it is expected that
stormwater issues will be discussed.
7.3.3 Public Notice
North Carolina law requires that city council hold public hearings before taking certain actions, such
as adopting changes in stormwater utility rates. The responsible person for these changes is the
Assistant Public Works Director, Stormwater & GIS Services.
Other parties are responsible for meeting other notice provisions.
Notice of city construction projects: Session Law 2015-246 (H44) section 12(b) requires cities to
provide written notice to property owners and adjacent property owners at least 15 days in advance.
The project manager or department director for the project is the responsible party for these notices.
City policy PA-5 covers Public Notification of Planned Service Interruptions and identifies notice
requirements for projects having low, medium, and high impacts on service. The project manager is
the responsible party.
Sanitary sewer overflows of 1,000 gallons or more must notify DEQ within 24 hours. If a sanitary
sewage discharge of 1,000 gallons or more reaches surface waters of the state, the operator must
also issue a press release to all print and electronic news media that provide coverage in the county
where the discharge occurred. If a sanitary sewer discharge of 15,000 gallons or more reaches
surface waters of the state, the operator must additional publish a notice of discharge in a county
newspaper and in each county downstream of the discharge point that may be affected by the
discharge. These most recent requirements were published in Session Law 2014-122. The
Superintendent, Water and Sewer Maintenance issues these press releases.

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7.4 Illicit Discharge Detection and Elimination
Objectives for Illicit Discharge Detection and Elimination
The City’s illicit discharge detection and elimination program is designed to meet or exceed the
following permit objectives:
• Detect and eliminate illicit discharges and connections, including preventable spills and illegal
dumping, to the municipal stormwater system owned and operated by the City of Durham.
• Implement appropriate enforcement procedures and actions.
• Maintain a map showing the permittee’s major MS4 outfalls to state receiving waters.
• Inform employees, businesses and the general public of hazards associated with illegal discharges
and improper disposal of waste.
• Prohibit non-stormwater discharges or flows from entering the drainage system, accept as allowed in
Part I, Paragraph 9.
The National Urban Runoff Program found poorer water quality associated with areas of older
development than for any other land use. There are many reasons for this difference. Construction
inspection and supervision, construction standards and materials have improved over time.
Weathering, settling, wear-and-tear and other factors have led to functional decline as infrastructure
ages. Older areas are served by pipes that leak or break, and have cross-connections that may have
been allowed previously or may have resulted from lack of care or supervision. According to the EPA
(1993), for many pollutants illicit discharges contribute a larger portion of the total mass discharged
from a storm drain system than stormwater runoff. Finding and eliminating the source of pollution is
essential for restoring and protecting water quality in cities with older development. An effective
IDDE program is also one of the most cost-effective means of meeting pollution reduction goals.
Durham is an historic community with some development dating back to the 1800s. The City has
found many illicit discharges where the City has older infrastructure. An effective IDDE program is
therefore essential to the success of the SMP.
The City began developing and implementing its IDDE program in 1994. Since then, it has continued
to refine its implementation by using multiple strategies, indicators, and techniques that have proven
successful over time (as discussed in Section 3.1.1).
The City will continue to maintain an effective IDDE program as generally outlined below.

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Table 7-3: BMP Summary Table for the IDDE Program
BMP Description Measurable Goals Frequency Responsible
Position
(a) Maintain
appropriate legal
authorities to
prohibit illicit
discharges and
illicit connections
Maintain Stormwater Management and
Pollution Control Ordinance to extent
authorized under State law.
Ongoing
Water Quality
Manager Review experience with enforcement of
Stormwater Pollution Control Ordinance
and evaluate need for minor
adjustments.
Annually
(b) Maintain a
Storm Sewer
system Base Map
of Major MS4
Outfalls
Maintain a current map showing major
outfalls and receiving streams. Ongoing
SW Billing &
GIS
Administrator
(c)
Inspection/
Detection Program
to Detect Dry
Weather Flows at
MS4 Outfalls

Maintain written procedures for
inspecting and screening major outfalls
and for identifying other outfalls to
inspect/screen, including timeframe,
areas to be targeted, and number of
outfalls.
Ongoing
Water Quality
Specialist
(inspection,
enforcement)
Maintain procedures to investigate
concerns and complaints related to illicit
discharges and connections.
Ongoing
Maintain procedures for removing the
sources or reporting the sources to the
State to be properly permitted.
Ongoing
(d)
Training of
Municipal
Employees
Involved in IDDE
Conduct training for new municipal staff
involved with dry weather screening. Ongoing
Water Quality
Specialist
(inspection,
enforcement)
Conduct training for municipal staff
involved with investigating and enforcing
prohibitions against illicit discharges and
connections on detecting and
documenting illicit discharges.
Ongoing
Identify work groups of municipal
employees likely to encounter illicit
discharges and provide training on
identifying and reporting illicit discharges.
Ongoing
Pollution
Prevention
Coordinator
(e)
Maintain Public
Reporting
Mechanisms
Continue to promote and maintain
pollution reporting hotline (560-SWIM)
and other means for public reporting of
illicit discharges. .
Ongoing
Water Quality
Specialist
(inspection,
enforcement)
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Table 7-3: BMP Summary Table for the IDDE Program
BMP Description Measurable Goals Frequency Responsible
Position
Regularly publicize mechanisms for the
public to report illicit discharges as
discussed in Section 7.2.
See also Table
7.2 (e)
Public
Education
Coordinator
(f) Documentation
Continue to maintain database
documenting outfall inspections. Ongoing
Water Quality
Specialist
(inspection,
enforcement)
Continue to maintain a database and file
system to track dates of initial and follow-
up investigations, photos and other
evidence, enforcement, actions taken by
the responsible party, etc.
Ongoing
Continue to maintain a database and file
system to track dates of initial and follow-
up investigations, photos and other
evidence, enforcement, actions taken by
the responsible party, etc.
Ongoing

7.4.1 Legal Authorities
Legal authorities are provided under the Stormwater Management and Pollution Control Ordinance
(Durham City Code Chapter 70, Article V, Section 70-492 through 70-542) ( see Stormwater
Management Plan Appendix A), which allows the City to identify and remove non-stormwater
discharges that convey significant pollutants. Allowable and prohibited discharges under the
ordinance are consistent with permit provisions in Part 1, I(1) and I(1) of the City’s 2018 permit. The
ordinance covers discharges to any part of the drainage system, and includes discharges to privately
owned drainage in addition to discharges to the city’s Municipal Storm Sewer System. The ordinance
also requires businesses engaged in certain activities to implement pollution prevention practices to
reduce the likelihood of spills and other pollution sources. The ordinance authorizes multiple
administrative, judicial, and criminal options for progressive enforcement, as necessary. In specific
instances, the City’s illicit discharge program may coordinate with other city and county departments,
and other regulatory mechanisms may also be employed to achieve compliance.
Methods used by the City of Durham to locate and eliminate illicit discharges continue to evolve. The
City periodically updates the following documents:
• Outfall Screening and Monitoring Standard Operating Procedures
• Industrial Outfall Screening and Monitoring Standard Operating Procedures
• Illicit Discharge Detection and Elimination (IDDE) Investigations Standard Operating Procedures
• Stormwater Inspections Program Standard Operating Procedures
• Stormwater Inspections Database User-Administrator Guide
• Guidelines for Enforcement of the Stormwater Management and Pollution Control Ordinance
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7.4.2 Ordinance Administration and Enforcement
The Stormwater Management and Pollution Control Ordinance authorizes a range of violation
remedies. The most commonly used remedy is an administrative enforcement process under which
the ordinance provides for notices and civil penalties.
Detailed administration and enforcement procedures have been developed for this administrative
enforcement process, including guidelines for issuing Notices of Requirement (NOR) and Notices of
Violation (NOV). The City maintains a set of digital example files for Notices that include commentary
and guidance. The City automated the computation of proposed penalties for citable violations. The
database in which investigations are recorded is able to compute civil penalty amounts, taking into
account factors that are required to be considered under the ordinance. Proposed penalties are
provided with each NOV. The ordinance provides that the accused may request an explanatory
meeting to discuss the City’s evidence and to provide additional evidence, including mitigating or
exculpatory information. The accused may also submit written evidence or information. Penalties
may be waived in part or completely based on information and evidence provided, including actions
taken by the responsible party.
Other remedies authorized by the ordinance may be implemented in rare situations where our typical
administrative process does not achieve compliance.
Investigations and enforcement are tracked and documented in a multi-user database. A map
function in the database allows investigators to determine whether there have been previous
violations at a given location.
7.4.3 Storm Water System Inventory
The Stormwater and GIS Division has available extensive GIS mapping resources that are helpful in
guiding efforts to locate and eliminate illicit discharges. Stormwater system components include
inlets, outlets, pipes (12 inches and larger), culverts, etc. on public and private property. Streams,
ponds and lakes are available. Drainage watersheds (sewersheds) have been delineated by major
stream. The City has a well-developed process for updating these map features.
The City requires that new development projects conduct video inspection of stormwater piping
systems, and to correct issues and re-submit video prior to project acceptance. The City also requires
submittal of digital as-built drawings to facilitate updating and maintaining system base map and
inventories.
7.4.4 Assessment and Evaluation of IDDE Program
Stream monitoring is conducted for a variety of purposes, including to guide IDDE efforts. Annually,
the City assesses monitoring results. Monitoring results are also used to inform the seasonal focus
of the Outfall Screening Program.
In addition, the Water Quality Unit conducts monthly assessment of performance indicators for the
IDDE program related to workload, productivity, and outcomes. A few key indicators are reported in
the Public Works Department’s Strategic Plan database to communicate results to the Public Works
Director and City management.
Assessment and evaluation allow tracking of changes in workload over time, changes in efficiency,
need for follow-up investigations, categorization of the types of pollutant source eliminated, which
reporting mechanism was used to trigger each investigation, etc. Assessment can result in modifying
approaches.
Summaries of interesting assessment results are typically included in annual reports.
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7.4.5 Training of Municipal Employees Involved in Implementing the IDDE Program
New technical staff hired to implement the IDDE Program have four-year degrees in science. Initial
training of new staff includes document review, job shadowing, and supervised field work.
Formal training generally occurs after new hires have successfully completed job shadowing, are
oriented to procedures, processes, and systems and are able to lead a simple investigation. Formal
training uses PowerPoint presentations with photo examples to cover various aspects of
investigations and enforcement. Formal training typically requires two to three half-day sessions,
and includes written testing to assess understanding.
7.4.6 Reporting Mechanisms
The Stormwater and GIS Services Division maintains multiple methods for the public to report
pollution concerns. In addition to the pollution reporting hotline (Table 7.2(c) and 7.3(e)) uses and
promotes the following reporting mechanisms:
• Pollution hotline (919) 560-SWIM
• Group e-mail address, [e-mail]
• Online reporting form is operational on the Stormwater & GIS Services web site
• Durham One Call [phone] telephone service that serves as a central point of contact for
information and services offered by the City of Durham.

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7.5 Construction Site Stormwater Runoff Control
The construction site stormwater runoff control program is designed to meet or exceed the following
permit objectives:
• Reduce pollutants in stormwater runoff from construction activities, within the permittee’s regulatory
jurisdiction, disturbing one or more acres of land surface and those activities less than one acre that
are part of a larger common plan of development.
• Provide procedures for public input, sanctions to ensure compliance, requirements for construction
site operators to implement appropriate erosion and sediment control practices, review of site plans
which incorporates consideration of potential water quality impacts, and procedures for site inspection
and enforcement of control measures.
• A locally delegated program that meets the state requirements and that covers the jurisdictional area
of the permittee complies with the required minimum measures of this permit.
North Carolina has a well-established program to address the impacts of construction site runoff.
This program pre-dates federal requirements in municipal stormwater permits. The Sediment
Pollution Control Act of 1973 as amended, NCGS chapter 113A Article 4, established the North
Carolina Sedimentation Control Commission to regulate construction site erosion and sedimentation.
The Commission promulgated Chapter 4 of Title 15A of the North Carolina Administrative Code,
specifying standards and requirements, with the North Carolina Department of Environmental
Quality, Division of Energy, Mineral and Land Resources, Land Quality Section as the primary
regulatory authority.
The Sedimentation Pollution Control Act of 1973 and the rules adopted pursuant to the Act
(hereinafter collectively “SPCA”) allow for the North Carolina Sedimentation Control Commission to
delegate jurisdiction to agencies for certain types of projects, provided the program has been
approved by the Commission. To facilitate delegation, the Commission:
• Develops manuals and publications to assist in the design, construction and inspection of erosion and
sedimentation control measures;
• Conducts educational programs in erosion and sedimentation control directed toward persons
engaged in land-disturbing activities;
• Provides instructional materials for persons involved in the enforcement of the SPCA and its
regulations;
• Conducts periodic review of delegated programs, providing recommendations to improve program
administration; and
• Provides technical assistance in review of draft erosion and sedimentation control plans for complex
activities.
Within the City of Durham there are three programs that are authorized to implement the SPCA,
permit and inspect construction-related land disturbing activity in Durham. The following summarizes
the authorities of each:
• Durham County Stormwater and Erosion Control Division’s erosion control program: construction
projects by entities that do not have the power of eminent domain (private projects, covers most
construction).
• North Carolina Department of Transportation: state road construction projects.
• North Carolina Division of Energy, Mineral and Land Resources, Land Quality Section has exclusive
jurisdiction over land disturbing activities that are conducted by the State, by the United States, by
persons with the power of eminent domain other than a local government, projects by a local
government or which are funded in whole or in part by the State of the United States or which related
to oil and gas exploration on the well-pad; the Land Quality Section also maintains independent
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authority over projects regulated by delegated programs operated by Durham County and the
Department of Transportation.
7.5.1 Durham County Erosion Control Program
Within the City and County of Durham most construction projects are privately funded. Durham
County Stormwater and Erosion Control Division’s erosion control program has delegated regulatory
authority for these projects.
Having erosion control regulated as a county-wide program is consistent with most other aspects of
land development regulation in Durham, which is guided by a City-County Comprehensive Plan and
regulated under a City-County Unified Development Ordinance, which is implemented by a City-
County Planning Department. The city does not exercise authority over an extra-territorial jurisdiction
zone, and thus does not have regulatory authority outside of city corporate limits. With county-wide
regulation, there is no need for project hand-off between county and city for projects initiated outside
city limits that have agreed to voluntary annexation at some future date in exchange for extension of
city utilities. Durham County’s erosion control program provides uniform application of standards,
and continuous and consistent oversight of regulated projects through all phases of development.
Durham County has a long history of regulating sediment and erosion control. The Durham County
Board of Commissioners adopted a Commission-approved ordinance on September 10, 1984,
becoming one of the first delegated local programs in North Carolina. The Durham County Board of
Commissioners agreed to enforce the ordinance within the City of Durham, and the Durham City
Council adopted a Resolution authorizing the enforcement of this ordinance within the City of
Durham on October 1, 1984.
In 2006, the City and County replaced separate zoning and subdivision ordinances with a Unified
Development Ordinance (UDO). The City-County UDO includes the most current local erosion and
sedimentation control regulations. The UDO provisions applicable to sedimentation and erosion
control are primarily found in Appendix D to this Stormwater Management Plan, and include Sections
3.8, 12.10, 15.1, and 15.5. Appendix C to this Stormwater Management Plan provides Section 8 of
the UDO, which includes steep slope provisions of Section 8.8. Definitions are found in Section 16 of
the UDO.
The North Carolina Sedimentation Control Commission periodically reviews the UDO’s erosion and
sediment control requirements. The Commission also reviews program implementation by the
Durham County Stormwater and Erosion Control Division, which continues to meet or exceed criteria
established by the Commission. The program will continue to be monitored by the state to ensure the
County effectively meets or exceeds the maximum extent practicable standard established by the
Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina
Administrative Code.
Applicability requirements under the UDO exceed requirements of both the SPCA and the federal
stormwater regulations to control stormwater runoff from land disturbing activities that exceed one
acre (43,560 square feet). Section 12.10 of the UDO requires a permit for land-disturbing activity
that disturb 12,000 square feet or more, and an approved, engineered erosion and sedimentation
control plan (hereafter referred to as “approved ESC plan”) for sites that disturb more than 20,000
square feet. In determining the applicable disturbed area, lands under one or diverse ownership
being developed as a unit (i.e. as a common plan of development) will be aggregated. Sites that
disturb less than 12,000 square feet are exempt from obtaining a permit prior to initiating land-
disturbance; notwithstanding this exemption, an erosion control plan and/or permit may be required
by the Sedimentation and Erosion Control Officer when off‐site damage is occurring, or if the
potential for off‐site damage exists.
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Applications for land disturbance permits are reviewed separately from site plans. Under Section
3.8.1 of the UDO, if required under Section 12.10, an approved sedimentation and erosion control
plan or a land-disturbing permit must be obtained before commencing land disturbing activities.
Durham County Stormwater and Erosion Control Division’s erosion control program includes
procedures for public input, sanctions to ensure compliance, requirements for construction site
developers to implement appropriate erosion and sediment control practices, review of site plans
that incorporate consideration of potential water quality impacts, periodic site inspection, and
procedures for enforcement of control requirements (described in Appendix E). The program also
includes qualification and experience requirements for the Erosion Control Technician positions
including, “…graduation from a technical institute or community college with a major in Engineering
Technology and some experience in engineering plan review or an equivalent combination of
education and experience.” Program review is facilitated by an internal database to track project
reviews and site inspections. Ordinance requirements were revised and updated in 2009.
The City continues to promote the City’s Pollution Reporting Hotline as a means that the public may
report water quality concerns, including observed erosion and sedimentation problems. The County
is developing a Muddy Water Watch App for reporting erosion and sedimentation issues that will
tentatively be released in March, 2019.
The Durham County Stormwater and Erosion Control Division’s erosion control program is funded
through erosion control fees. This funding mechanism allows staffing levels to be adjusted based on
the construction activity levels.
7.5.2 North Carolina Department of Transportation
North Carolina Department of Transportation maintains self-review and self-inspection programs for
state road construction projects. The North Carolina Land Quality Section maintains independent
authority over these projects.
7.5.3 North Carolina Land Quality Section
The Land Quality Section, North Carolina Division of Energy, Mineral and Land Resources regulates
land disturbing activity for construction projects that have public funding, projects by persons with
the power of eminent domain, and projects by state and federal agencies. Cities, towns and counties
are considered agencies of the state.
The Land Quality Section operates a state-wide hotline, 1-866-STOPMUD. Land Quality Section staff
at the Raleigh Regional office are responsible for plan review and permitting within a 16 county area.
Many of the counties in the region do not have delegated programs, and in these counties, the
regional offices is responsible for permitting and inspecting erosion and sediment controls at
privately funded construction sites that disturb more than one acre. The Land Quality Section also
maintains independent authority over projects regulated by delegated programs operated by Durham
County and the Department of Transportation and periodically conducts inspection of their projects.
With such a large area to cover, response times are longer.
7.5.4 City Reliance-On and Coordination-With Authorized Programs
As authorized by the City’s permit, the City will continue to rely on these three entities to comply with
this minimum measure. Each of these programs meets or exceeds federal regulations requiring
permitting and controlling development activities disturbing one or more acres of land surface and
those activities less than one acre that are part of a common plan of development.
Reports from city employees or members of the public received via the City’s Pollution Reporting
Hotline or other means described in Section 7.4 of the Stormwater Management Plan may include
concerns related to construction sites. As part of the municipal employee training discussed in
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Section 7.7, city engineering inspectors have been trained to identify and report illicit discharges.
Construction-related illicit discharges, such as washing out ready-mix concrete trucks to the drainage
system, are addressed under the City’s Stormwater Management and Pollution Control Ordinance,
discussed in Section 7.4. While the City is not authorized to implement the SPCA, the City ordinance
provides independent authority to investigate and to conduct enforcement when sediment leaving a
construction site is accumulating off-site in City streets, City storm drains or other parts of the
drainage system, including waterways within the city. The City is beginning to develop a draft
standard operating procedure to guide inter-agency coordination with the County, including
determination of authorized SPCA agency for a given project.
Investigations conducted by City staff will continue to be tracked in the City’s investigations
database. Trends will continue to be reported in in the illicit discharge section of annual reports.
o Post-Construction Storm Water Management in New Development and
Redevelopment
Permit NCS000249 requires the City to develop, implement, and enforce a program of post-
construction stormwater runoff controls for new development. The objectives of the program
include:
• Managing stormwater runoff from new development/redevelopment that drains to the MS4
and that cumulatively, since the baseline date applicable to that area of the City, disturbs
more than the applicable threshold 20 (including projects that disturb less than the threshold
but are part of a larger common plan of development or sale).
• Providing a mechanism to require long-term operation and maintenance of structural
stormwater Best Management Practices (BMPs).
• Ensuring controls are in place to minimize water quality impacts.
Although major ordinance changes were adopted in 2012, most of the City’s post-construction
stormwater management program has been in place for many years, as described in Section 3.1.
For development on land draining to nutrient sensitive waters (NSW), NCS000249 Part II (F)(2)(c)
requires the City to develop, adopt, and implement an ordinance to ensure that the best
management practices for development reduce nutrient loading to the maximum extent practicable.
NCS0000249 Part I (11) requires the City to continue to implement provisions of the current
Stormwater Plan “until the Division approves any revisions to the Stormwater Plan.”
The table below summarizes the BMPs to be implemented and maintained during the remainder of
the permit to meet the objectives of the Post-Construction Stormwater Management Program. Text
sections that follow the table further explain the management measure intended to meet this
requirement.

20 The disturbance thresholds in the City of Durham’s Stormwater Performance Standards for Development
ordinance are all equal to or less than the threshold listed in the City of Durham’s NPDES permit.
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Table 7.4 BMP Summary Table for the Post-Construction Stormwater Management Program21
BMP Description Measurable Goal Timeline Responsible Position
(a) Post-Construction
Stormwater
Management Program
Maintain an ordinance (or similar regulatory
mechanism) that authorizes a program to address
stormwater runoff from new development and
redevelopment to the extent allowable under State
law.
Ordinance has been
developed,
implementation ongoing.
Stormwater Development
Review Supervisor
Maintain the Reference Guide for Development and
City of Durham Addendum to the NC DWQ
Stormwater Best Management Practices (BMP)
Manual.
Implementation is
ongoing; changes will be
made where needed to
insure all policies are
clear, to improve BMP
design standards, or as
new or better information
becomes available.
Stormwater Development
Review Supervisor
Continue to implement the City’s stormwater
development review process, which includes site
plan and construction drawing review, to ensure
compliance with the ordinance and BMP design
standards.
Ongoing Stormwater Development
Review Supervisor
Maintain the City’s stormwater SCM as-built
approval process.
Ongoing Stormwater Development
Review Supervisor
Further Improve and add additional functionality to
the Stormwater Control Measure (SCM) Tool (“the
Tool”).
Ongoing Stormwater Development
Review Supervisor
Train Stormwater Development Review staff. Ongoing Stormwater Development
Review Supervisor

21 The letters in the left hand column of this table reference the associated table of management measures for the Post Construction Stormwater Management
Program in the City’s NPDES Permit NCS000249. This table starts on Part II, Page 6 of 15.
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BMP Description Measurable Goal Timeline Responsible Position
(b) Strategies which
include BMPs
appropriate for the MS4
Maintain strategies that include a combination of
structural and/or non-structural BMPs implemented
in concurrence with (a) above. Provide a
mechanism to require long-term operation and
maintenance of structural SCMs. Require annual
inspection reports of permitted structural SCMs
performed by a qualified professional.
A qualified professional means an individual trained
and/or certified in the design, operation,
inspection, and maintenance aspects of the SCMs
being inspected, for example, someone trained and
certified by the NC State for BMP Inspection &
Maintenance.
Ongoing; see (d) below Stormwater Development
Review Supervisor
Continue to require Stormwater Impact Analysis for
each development project.
Ongoing Stormwater Development
Review Supervisor
Continue to require treatment for pollutants (in
addition to nitrogen and phosphorus) in areas for
which Total Maximum Daily Loads (TMDLs) have
been established for those pollutants.
Ongoing Stormwater Development
Review Supervisor
(c) Deed Restrictions,
Protective Covenants
The permittee shall provide mechanisms such as
recorded deed restrictions, plats, and/or protective
covenants so that development activities maintain
the project consistent with approved plans.
Ongoing Stormwater Development
Review Supervisor
Use recorded conservations easements to protect
property.
Ongoing Stormwater Development
Review Supervisor
(d) Operation and
Maintenance Plan
The developer shall provide the permittee with an
operation and maintenance plan for the stormwater
system, indicating the operation and maintenance
actions that shall be taken, specific quantitative
criteria used for determining when those actions
shall be taken, and who is responsible for those
actions. The plan must clearly indicate the steps

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BMP Description Measurable Goal Timeline Responsible Position
that shall be taken and who is responsible for
restoring a stormwater system to design
specifications if a failure occurs and must include a
legally enforceable acknowledgement by the
responsible party. Development must be
maintained consistent with the requirements in the
approved plans and any modifications to those
plans must be approved by the Permittee.
For each structural BMP required by ordinance,
require a recorded plat signed by the property
owner(s) that acknowledges long-term operation
and maintenance.
Ongoing Stormwater Development
Review Supervisor
For each completed structural BMP required by
ordinance, require an operation and maintenance
plan, i.e. O&M Manual, which lists specific
inspection and maintenance activities required to
ensure the proper functioning and upkeep of a
particular BMP. The property owner/permittee is
responsible for maintaining the facility per the
recorded stormwater facility agreement, and City
ordinance.
Ongoing Stormwater Development
Review Supervisor
Require annual inspection reports of permitted
structural BMPs performed by a qualified
professional.
Ongoing Stormwater Development
Review Supervisor
Conduct annual quality assurance inspections on a
portion of all reports, including at least one from
each certified inspector submitting reports.
Ongoing Stormwater Development
Review Supervisor
(e) Educational materials
and training for
developers
Provide educational materials and training for
developers. New materials may be developed by
the permittee, or the permittee may use materials
adopted from other programs and adapted to the
Ongoing Stormwater Development
Review Supervisor
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BMP Description Measurable Goal Timeline Responsible Position
permittee’s new development and redevelopment
program.
Conduct seminars for engineers, architects, and
developers at least twice a year.
A minimum of two
workshops are conducted
annually.
Stormwater Development
Review Supervisor
Distribute information on post-construction
program changes via the “Development
Community” e-mail list.
E-mails sent on an as-
needed basis.
Stormwater Development
Review Supervisor
Conduct voluntary BMP handoff meetings with
developers and Homeowner’s Associations of
single-family residential subdivisions.
As requested by
subdivision developer
and HOA.
Stormwater Development
Review Supervisor
1.

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7.5.5 Post Construction Stormwater Management Program
The City of Durham’s post construction stormwater management program includes the following elements:
• Ordinances to address stormwater runoff from new development,
• BMP design standards,
• A development review process to ensure compliance with the ordinance and BMP design standards,
• A BMP as-built approval process to ensure a BMP was constructed as it was designed,
• An operation and maintenance program to ensure a BMP continues to operate as it was designed,
• The SCM Tool, a database used to track projects and BMPs, and
• Training for stormwater development review staff.
These program elements are discussed below, with the exception of the operation and maintenance
program, which is discussed in Section 7.6.5.
7.5.5.1 Ordinances
Prior to adoption of a Phase II post-construction ordinance in 2009, the City of Durham had been
implementing state-mandated programs that require and enforce post-construction management of storm
water discharges. Water supply watershed protection requirements (discussed in Section 3.1.2) meet or
exceed requirements of 15A NCAC 2B.0215 and 2B.0216. The City’s Neuse River Stormwater Ordinance
(discussed in Section 3.1.6) complied with 15A NCAC 2B.0235. Together, the Water Supply Overlay and
Neuse Stormwater ordinance covered approximately 60% of the City, as shown in Figure 7-5 below.
To comply with the post-construction requirements of the City’s NPDES municipal permit, the City adopted an
ordinance that became effective March 17, 2009. This ordinance went beyond Phase II minimums and
included nitrogen export limits and 1-year peak flow controls imposed citywide, essentially extending the
City’s Neuse requirements throughout the City.
Anticipating the need for more stringent controls on nutrients, effective June 15, 2010, the City Council
adopted revisions to the Stormwater Performance Standards for Development to enhance protection of
water quality. Nitrogen export limits were reduced from 3.6 pounds per acre per year, to 2.2 pounds per
acre pre year, and a phosphorus export limit of 0.5 pounds per acre per year was added. These limits
applied citywide.
Additional revisions became effective July 6, 2012 with the adoption of an ordinance approved by the NC
Environmental Management Commission for compliance with Jordan Lake Nutrient Strategy and Falls Lake
Nutrient Strategy. The Jordan Lake Nutrient Strategy has since been repealed –areas located in the City of
Durham and Jordan Lake Basin but outside of the Jordan Lake Water Supply Watershed boundary are
subject to Phase II requirements.
The current ordinance is Chapter 70, Article X, Sections 70-736 through 70-744, and a link to the ordinance
can be found on our web site at the bottom of http://durhamnc.gov/895/Stormwater-Development-Review.
This code section contains post-construction performance standards applicable throughout the City that
address both general Phase 2 post-construction requirements and Nutrient Management Strategy
requirements. The City-County Planning Unified Development Ordinance (UDO), which governs development
within the City, makes reference in Section 12.8 to the City Code indicated above. The post-construction
ordinance has been adopted as a City development performance standard, rather than through amendment
of the UDO, since Durham County is not required to obtain a Phase 2 NPDES Municipal Stormwater Permit.
Performance standards are generally not subject to vesting in the same manner as changes in planning and
zoning requirements.

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The ordinance applies to projects that exceed minimum land disturbance thresholds shown in Table 7.5
below, and to smaller projects that are part of a larger common plan of development. The ordinance is
implemented through the City’s stormwater development review process.
Table 7.5 Thresholds for Application of Stormwater Pollutant Requirements
Project Location Land Disturbance
Limited Residential Multifamily and Other
Jordan Lake Basin 1 acre 1 acre
2. Falls Lake Basin 0.5 acre 12,000 sq. ft.
Lower Neuse Basin 1 acre 0.5 acre

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Figure 7-5: City of Durham Post-Construction Stormwater Treatment

Nutrient yield limits on nitrogen and phosphorus under the ordinance are shown in Figure 7-5 and the table
below.
Table 7.6 Nitrogen and Phosphorus Post-development Loading Limits
Project Location Export Limit (pound/acre/year)
Nitrogen Phosphorus
• Falls Lake Basin 2.2 0.33
Lower Neuse Basin 3.6 Not required

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Concurrent with the effective date of the 2012 ordinance, the City mandated use of the Jordan/Falls Lake
Stormwater Nutrient Loading Accounting (JFSAT) Tool developed by NC DENR for calculation of pre- and post-
development loadings from all development sites. The JFSAT Tool is currently required for all projects.
Beginning April 15th, 2019, the latest version of the Stormwater Nitrogen and Phosphorus (SNAP) Tool will
replace the use of the JFSAT Tool for projects located within the Falls Lake Basin, as well as the Jordan Lake
Basin. As soon as the City adopts revised stormwater performance standards to remove the Jordan Basin
New Development Regulations in Spring 2019, the need for the use of a nutrient load accounting tool in the
Jordan Basin will be removed as well. The JFSAT Tool will continue to be required in the Lower Neuse Basin
until such time NCDEQ revises/readopts the Neuse nutrient sensitive waters management strategy.
Water Supply Overlay ordinance provisions of the City-County UDO include density limits and other
provisions, and remain as independently applicable requirements. While the water supply watershed
protection ordinance also includes water quality treatment, the treatment provisions are less stringent than
those of the Stormwater Performance Standards for Development.
The City will continue to implement and enforce these ordinances, making text revisions as needed for
clarity, legal purposes, etc.
7.5.5.2 BMP Design Standards
To regulate stormwater control measure design and construction, the City of Durham currently utilizes the
following:
• The 2009-2016 addition of the North Carolina Division of Water Quality Stormwater BMP Manual and its
associated BMP Manual Errata Sheet. These documents can be viewed or downloaded from the Division of
Energy, Mineral and Land Resources’ website at https://deq.nc.gov/node/84034.
• The City of Durham Addendum to the State Manual, which can be found under the City’s Stormwater
Development Review webpage at http://durhamnc.gov/895/Stormwater-Development-Review.
The addenda are the City of Durham’s additions, clarifications, and exceptions to the NC DWQ’s stormwater
BMP Manual.
The City will maintain its Reference Guide for Development and City of Durham Addendum to the State BMP
Manual, making changes to these documents where needed to address specific regional issues, improve
BMP design standards, or as new or better information becomes available.
7.5.5.3 Development Review Process
The City’s Post Construction Stormwater Management Program utilizes a development review process, with
associated guidance and policy documents, to implement the ordinance. When reviewing and approving
development plans, the City uses a two stage process: Site plans, which show the layout of a development
and the location of all utilities (including BMPs), are approved first. A site plan will not be approved if it does
not meet the Stormwater Performance Standards for Development requirements.
Following the approval of the site plans, construction drawings are submitted for review and approval. The
construction drawings contain the specific details of the development, including the plans, profiles, and
design details of all proposed BMPs. The City’s Reference Guide for Development, which can be found on
our web site at http://durhamnc.gov/DocumentCenter/View/3331.
Both site plans and construction drawings are required to be prepared by registered professionals.
Stormwater details on construction drawings must be signed and sealed by a Professional Engineer licensed
in North Carolina. The City’s stormwater plan review is conducted by NC-licensed Professional Engineers, or
by Engineer Interns under the supervision of an NC-licensed Professional Engineer.
In conjunction with the 2012 revisions to the post-construction performance standards ordinance, the City
revised ordinance provisions regarding BMP inspection, maintenance, repair and reconstruction
responsibilities, and expanded the enforcement remedies to allow more tools to address noncompliance.

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The City will maintain its development review process, making changes to guidance documents and policies
where needed to obtain better results, or as new or better information becomes available.
7.5.5.4 As-built Approval Process
The City of Durham requires that the construction of a BMP be certified as to its actual constructed condition
in relation to the approved design for the facility. The Certification consists of the provision of as-built
drawings and supporting documentation demonstrating that the BMP was constructed in a manner that
accomplishes its designed functions. These Certifications must be submitted in accordance with the City of
Durham’s As-built Program and must be reviewed by the City’s Stormwater Development Review Section of
the Stormwater & GIS Services Division. Further information on the As-built program can be found in Section
8.6 of the Reference Guide for Development at
https://durhamnc.gov/DocumentCenter/View/3331/Reference-Guide-for-Development-?bidId= .
The City has historically implemented a Stormwater Building Permit and Certificate of Compliance Issuance
Operating Policy to ensure that developers don’t complete the development without completing the BMPs
(as described in the Letter to Industry: Stormwater Building Permit and Certificate of Compliance Issuance
Operating Policy, dated April 17, 2012). Under this policy, residential and commercial developments are
treated differently. For commercial developments, if the BMPs are not complete and the developer wants a
conditional Certificate of Compliance (also called a Certificate of Occupancy or CO), the developer must:
• Post a construction security to ensure completion of the BMPs, and
• Complete the BMPs in an established timeframe.
To obtain a final CO for a commercial project the developer must complete the BMPs and provide an
acceptable as-built package for them. Once the BMPs have been satisfactorily completed and the as-built
package has been accepted, the construction security is released
Residential developments are handled differently to reflect that BMPs are often used for erosion and
sediment control during construction, and to accommodate the developer’s cash-flow need to continue to
build and sell houses in order to complete the development. Thus, for residential developments, the policy
for building lots platted prior to October 1, 2015 ensures that BMP construction progresses along with lot
building by releasing building permits and COs in a progressive manner, however a construction security to
ensure completion of the BMPs must be provided when the first CO is requested. If the BMPs are not
complete and developer wants more building permits or COs, the developer must:
• Request in writing for consideration what additional lots they would like building permits or COs on, advise
what has been done recently (within last six months) to bring the BMP(s) to completion, and outline the
completion schedule with milestones to be met.
• Meet the milestones approved in the letter of request and complete the BMPs in an established timeframe.
The City places permit or CO holds in our application/permit tracking system (an enterprise software
platform called Land Development Office) to ensure the permit or CO holds remain so adequate leverage
beyond securities continues to keep the BMP(s) completion a priority for the developer.
The City’s reaction to Session Law 2015-187 changed the above policy for single family residential building
lots platted October 1, 2015 or later. The developer now must provide a BMP(s) construction security of their
choice for 125% of the reasonable estimated construction cost of the BMP(s) prior to final plat approval.
The City does not hold any building permits and the Session Law has no timeframe for the developer to
complete the BMP(s) as long as they are showing a good faith effort. This new law effectively stripped the
City of much of its leverage to ensure timely completion.
If the BMPs are not completed or good faith efforts toward completion are not witnessed, the City has some
options to obtain compliance, which includes calling the bond or demanding the construction security and
completing the BMPs, placing holds on building permits if any remain, holding approval of future plans if
within the same development, etc.

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The City will maintain its as-built approval process, making changes to guidance documents and policies
where needed to improve the process.
7.5.6 Strategies which include BMPs appropriate for the MS4
Through the Stormwater Performance Standards for Development ordinance and the Reference Guide for
Development, the City requires new developments to be analyzed for changes to both water quantity and
water quality. This analysis is called the “Stormwater Impact Analysis”.
For water quantity, project engineers must analyze increases in the 1-year, 2-year, and 10-year, and possibly
the 100-year or other peak flow if applicable impervious area thresholds are met. The purpose of these
analyses are to ensure that the increases in volume, velocity, and peak flow of stormwater discharges from
proposed developments are addressed, in order to mitigate the impacts on downstream properties,
stormwater infrastructure, and conveyance systems.
The City of Durham currently requires the submission of a Stormwater Impact Analysis for all land
development activities when applicable impervious area and/or disturbance thresholds are met. If the
impervious cover proposed in the plan would increase the peak runoff rate during the 1-year event,
detention of the 1-yr event will be required. If an increase in the 2- and 10-yr peak runoff rates is proposed,
detention and/or offsite drainage improvements may be required at the discretion of the Department
Director or his/her designee. However, the City usually defaults to a 10% rule before requiring mitigation. In
the instance of infill developments, detention of the 100-yr event may be required to mitigate against
increases in yard or structural flooding immediately downstream of the proposed development. Developers
must provide stormwater BMPs to detain peak flows from any or all of these design storms as necessary to
mitigate impacts.
The City utilizes project-scale modeling tools for assessing nitrogen and phosphorus treatment by BMPs for
development and re-development projects. Beginning April 15th, 2019, the latest SNAP Tool will be required
for projects located within the Falls Lake Basin. Prior to April 15th, 2019 the JFSAT will be required for
projects located within the Falls Lake Basin. The JFSAT tool is required for projects located within the Lower
Neuse Basin. The City has adopted the latest approved version of the JFSAT to evaluate BMP performance
for nitrogen and phosphorous. The JFSAT was developed by NCDENR and approved by the NC Environmental
Management Commission. The JFSAT calculates nitrogen and phosphorus loading for development by
assigning mean nutrient concentrations to the stormwater runoff, volume reductions for differing land uses
and BMPs, and nutrient removal efficiencies for BMPs. With the recent revisions to the City’s ordinance and
usage of the Tool, post-construction BMP selection is guided by applicable nitrogen and phosphorous
loading limits and the effluent concentrations ascribed to the various BMPs. The Tool inherently promotes
the use of BMPs that control both concentration and volume of runoff to the extent allowed under 15A NCAC
2H .1008.
Per the Stormwater Performance Standards for Development ordinance, if reductions are needed to attain
nitrogen and phosphorus limits, a certain percentage of that reduction must be achieved onsite via
stormwater BMPs. Onsite goals often result in two BMPs in series or oversized BMPs. After meeting onsite
goals, the remaining percentage reduction may be purchased from nutrient banks.
The City also requires control of Total Suspended Solids (TSS). If disturbance thresholds are triggered and
the impervious percentage of a development that increases impervious area equals or exceeds certain
thresholds (24% for Falls, Jordan, and Lower Neuse Basins), TSS treatment is required. Impervious surfaces
must drain to a BMP that removes a minimum of 85% TSS during the 1-inch water quality event.
Although nitrogen, phosphorus, and TSS are the primary pollutants of concern with regard to development,
the City also requires control of other pollutants in areas for which a TMDL has been established. In
particular, the City requires control of fecal coliform bacteria in the Northeast Creek watershed, which has a
TMDL for that parameter. The Stormwater Performance Standards for Development ordinance requires at
least one BMP in a treatment train to be selected for bacteria removal, based on having a fecal removal
ability of high or medium in Table 4-1 of the NC Stormwater BMP Manual.

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The City of Durham also uses several non-structural BMPs to mitigate the effects of development. The City
has adopted Natural Resource Protection Standards as part of the Durham City/County Zoning Ordinance
(Section 8). These standards specifically address tree protection and tree coverage, floodplain protection,
stream buffer protection, steep slope protection, and wetlands protection. The City also has zoning
ordinances to direct growth to identified areas. Durham has a large area located in highly developed (WS-IV
classification) watersheds and currently has water supply watershed rules contained within its zoning
ordinances. Also, the City’s Park and Recreation Department and Planning Department manage a program
for maintaining and increasing open space. This program concentrates on preserving environmentally
sensitive and natural resource areas within the City including wetlands and riparian buffers.
The City will continue to require the Stormwater Impact Analysis to identify whether a development needs
one or more BMPs to comply with stormwater requirements, and which BMPs are appropriate.
7.5.7 Establish nutrient sensitive waters (NSW) protection measures (for programs with
development or redevelopment draining to NSW waters)
As discussed above in Section 7.6.1, land area within the City of Durham is currently subject to one of two
sets of State rules. These are listed in chronological order below:
• Neuse River Nutrient Sensitive Water Strategy
• Falls Lake Nutrient Sensitive Water Strategy
The Neuse River NSW Strategy required Durham and other local governments to adopt and implement
beginning in 2001 a post-construction ordinance for areas draining to the Neuse River Basin. The Falls Lake
NSW Strategy went into effect in 2010 and those rules require adoption of a post-construction ordinance in
2012.The Jordan Lake NSW Strategy went into effect in 2009 with the State rules requiring adoption of a
post-construction ordinance controlling nutrients from development and redevelopment also in 2012; these
requirements subsequently have been repealed and no longer apply beginning in spring 2019.
As shown in Figure 7-5, these two NSW Strategies collectively cover all of Durham that drains to Falls Lake
and the Lower Neuse River. The City has been implementing post-construction requirements for the Neuse
River NSW since 2004. Citywide nitrogen limits were included in the 2009 post-construction ordinance. The
ordinance was revised again in 2010 to implement interim nutrient loading limits for nitrogen and
phosphorous in advance of rule deadlines for Falls Lake and Jordan Lake. Effective July 6, 2012, the City
began implementing post-construction requirements for all three NSW rules. In the spring of 2019,
adherence to rules associated with the Jordan Lake Nutrient Sensitive Water Strategy will no longer be
required.
The city has been submitting an annual report for the Neuse River NSW Stormwater requirements. With
adoption of requirements for both the Jordan Lake and Falls Lake NSW strategy rules in 2012, annual
reports are required for the Falls regulations beginning in 2013. In 2012, the City began compiling
information about development plans approved in the Jordan Lake Basin, but annual reports have not been
required for the Jordan new development regulations. With the repeal of the Jordan Nutrient Water Strategy
annual reporting will not be required in spring 2019 or the foreseeable future.
The City will continue to maintain its ordinance which implements NSW protection measures.
7.5.8 Deed Restrictions and Protective Covenants
BMPs are constructed as part of private property developments. The City continues to use recorded plats
and recorded Operation and Maintenance Agreements (presently known as Stormwater Facility Agreements)
for all projects to indicate restrictions that convey with a property. Chapter 70 Article X Section 70-742,
Chapter 70 Article XI Sections 70-750 through 70-752, and UDO Section 8.7 require the recorded Operation
and Maintenance Agreements and the financial guarantees required to secure the operation and
maintenance of the BMPs. For limited residential development, the requirements under the Stormwater
Facility Agreement explicitly require an Owner’s Association, specific covenant language to ensure that a

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development project will continue to be operated and maintained consistent with approved plans, and
payment into the stormwater facility replacement fund managed by the City.
Impervious surface limits are required to be shown on recorded plats and are enforced by the City-County
Planning Department. The Building Inspections Department requires foundation surveys and final surveys to
ensure compliance. If building lots exceed allowed impervious cover during development of a subdivision,
plat revisions are required to balance impervious cover.
7.5.9 Operation and Maintenance
For each development project with one or more stormwater BMPs, the City’s Stormwater Performance
Standards for Development Ordinance requires approval and recordation of an agreement and/or covenants
that:
• Meet city stormwater standards, and
• Provide for the construction and long term maintenance, inspection, repair, and reconstruction of the BMPs in
accordance with City standards.
In the case of residential development intended for home ownership, the homeowners' association must be
created before the agreement and/or covenants are recorded, and must be a party to the
agreement/covenants.
The City ordinance and the recorded stormwater facility agreements require sealed annual maintenance
certifications (inspection reports) for all BMPs constructed and approved. The inspection report is a sealed
certification by a NC professional engineer or NC registered landscape architect who has been certified by
the City as a BMP maintenance certifier; this certification process includes completion of a City of Durham
approved BMP inspection and maintenance workshop, similar to the workshop offered by North Carolina
State University. The inspection report is submitted to Durham Stormwater & GIS Services following
procedures specified in the City’s BMP Annual Maintenance Certification Protocol.
Each inspection report is to include an operation and maintenance (O&M) manual for the facility. The O&M
manual lists specific inspection and maintenance activities required to ensure the proper function and
upkeep of a particular BMP. The City requires that all O&M manuals address the following, at a minimum:
• The frequency of inspections that are needed (based on the type of BMP proposed).
• The components of the BMP that need to be inspected.
• The types of problems that may be observed with each BMP component.
• The appropriate remedy for any problems that may occur.
• Inspection and maintenance records, which should be kept with the owner/responsible party.
In case of failures/deficiencies, the City continues to require a BMP maintenance certifier to develop a
remediation plan to bring the facility into compliance with the intent of the original design plans. The
remediation plan is to include an implementation schedule to be followed by the property owner. An
inspection report is required after the successful completion of all the remediation work.
The City reviews each submitted inspection report and conducts quality assurance (QA) site inspections on a
minimum of 50% of all reports. The selection of the 50% ensures that each BMP maintenance certifier is
included in the QA inspections. Additional information regarding the City’s BMP Annual Maintenance
Certification Program can found on the City’s webpage: http://durhamnc.gov/695/BCE-As-Builts-BMC-
Maintenance-Programs.
The City has adopted both hard and soft strategies, e.g. tiered compliance/enforcement strategies, to
increase the rate of compliance with the annual maintenance certification requirement. The first two tiers
are considered soft strategies which include educational documents, BMP handoff meetings (between
developers and homeowner associations), inspection reminder notices, and one-time warning notices. Tier
three strategies include notices of violations, opportunities to meet with the City to discuss violations,

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monetary civil penalty assessment notices, permit withholds, and demands for agreement securities. Tier
four strategies include judicial type actions and other related actions. Additional information regarding these
strategies can be found in the document titled “BMP Maintenance Certification Compliance Enforcement
Program – A Brief Overview.”
The City will continue to require a stormwater facility agreement, operation and maintenance plan, annual
compliance certification for each BMP. The City will also continue to conduct QA site inspections on a
portion of all annual compliance certification reports, and will continue to implement hard and soft
enforcement strategies to improve compliance rates.
Operation and Maintenance for Municipally-owned or Maintained BMPs: City Stormwater and GIS Services
staff conduct annual maintenance inspections of municipally-owned or maintained structural BMPs to verify
conditions, operational issues, and maintenance needs. These assessments are documented in formal
maintenance inspection reports annually. The City may perform maintenance and rehabilitation of city-
owned BMPs through periodic contracts with vendors that have experience in conducting this work, as well
as with city work crews.
7.5.10 Setbacks for Built-upon Areas
In lieu of the 30-foot setback provided in the state’s Phase II program, subdivisions and site plans are
required to protect 50-foot buffers on all perennial and intermittent streams, and ponds and lakes located in
a natural drainage way in accordance with the riparian buffer requirements in Section 8.5 of the UDO. Wider
buffers may be required under Water Supply Watershed overlay zoning districts.
A surface water is considered present if the feature is shown on either the most recent version of the soil
survey map prepared by the Natural Resources Conservation Service of the United States Department of
Agriculture or the most recent version of the 1:24,000 scale (7.5 minute) quadrangle topographic maps
prepared by the United States Geologic Survey (USGS). Relief from this requirement may be allowed when
surface waters are not present in accordance with the provisions of 15A NCAC 2B .0233 (3)(a). [See 15A
NCAC 2H .0126(11) for exceptions to 15A NCAC 2H .0126(10)(e)(i)(A)(III) and 15A NCAC 2H
.0126(10)(e)(i)(B)(IV).]
In November 2010 the City and County adopted substantial revisions to riparian buffer requirements in the
City-County UDO. These revisions were made largely to comply with Jordan Lake Nutrient Sensitive Waters
Strategy, 15NCAC 02B.0267 and .0268, but also to implement recommendations of the Environmental
Enhancements to the UDO Steering Committee and to consolidate buffer requirements in one section of the
UDO. The revised ordinance can be found online at http://durhamnc.gov/414/.
7.5.11 Educational Materials and Training for Developers
The City provides educational materials and training for developers in the following ways:
• At least two seminars per year for the development community on topics related to stormwater and
development review requirements in the City of Durham.
• Notification to its “development community” e-mail list regarding ordinance changes, changes to other
stormwater post-construction requirements and policies, training opportunities, and other information, on an
as-needed basis.
• Solicitation, via its “development community” e-mail list, of comments on changes to program implementation
documents, on an as-needed basis.
The seminars are presented by Stormwater and Engineering Development Review personnel. They include
design/review examples, updates on new engineering standards, revised ordinance requirements, operation
and maintenance plan elements, innovative BMP technologies, etc. Slides from the seminars are posted on
the City’s web site at http://durhamnc.gov/1607/ for those that were not able to attend. Outside speakers
may be invited to enhance learning and communication.

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Announcements to the development community are also posted on the Stormwater Services web site at
http://durhamnc.gov/905/. Letters to Industry policy documents are posted at
http://durhamnc.gov/1591/.
The City has begun a program to conduct voluntary BMP handoff meetings with developers and
Homeowner’s Associations (HOAs) of residential subdivisions. This meeting occurs after approval of the
BMP as-built drawings. The purpose of these meetings is to provide a smooth transfer of BMPs from the
developer to the HOA, and to educate HOAs about the BMPs in their subdivision and HOA responsibilities
and obligations regarding those BMPs.

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7.6 Pollution Prevention and Good Housekeeping for Municipal Operations

The objectives for this measure are to:
• Prevent or reduce stormwater pollution from municipal operations and municipal facilities.
• Train employees on how to incorporate Pollution Prevention and Good Housekeeping techniques into municipal
operations.
Pollution prevention and good housekeeping programs are an important factor in the improvement of
stormwater quality. Municipal maintenance facilities can be significant sources of pollution if not managed
properly. Other municipal activities, such as waste collection, offer significant opportunities to prevent
pollution and recycle materials. Recycling, household hazardous waste and oil collection, and street
sweeping are examples of some of the procedures that promote proper handling of materials to help prevent
pollution.
The table below summarizes the BMPs to be implemented and maintained during the remainder of the
permit under the pollution prevention and good housekeeping for municipal operations measure. Text
sections that follow the table further explain the BMPs intended to meet this requirement.
Table 7-7: BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations 22
BMP Measurable Goals Frequency Responsible
Position
(a) Inventory of
municipal
facilities and
operations
Maintain an inventory of municipal
facilities and operations owned and
operated by the permittee that have
been determined by the permittee to
have significant potential for generating
polluted stormwater runoff. Also
maintain an inventory of municipally-
owned structural SCMs.
Municipal facilities
inventory: ongoing
Water Quality
Specialist
(Investigations and
Inspections)
Municipally- owned
SCMs inventory:
ongoing
SCM Maintenance
Program
Coordinator
SCM inventory, see section 7.6
(b) Inspection and
maintenance
program for
municipal
facilities and
operations
Implement an inspection and
maintenance program for facilities and
operations owned and operated by the
permittee for facilities and operations
owned and operated by the City of
Durham for potential sources of
polluted runoff, including stormwater
controls and conveyance systems. The
inspection program shall evaluate
pollutant sources, document
deficiencies, plan corrective actions,
implement appropriate controls, and
document the accomplishment of
corrective actions. The maintenance
Facility inspections:
ongoing
Water Quality
Specialist
(Investigations and
Inspections)
Facility Maintenance:
ongoing
Pollution Prevention
Teams under
supervision of
facility
Superintendent(s)
SCM Inspection and Maintenance, see
section 7.6.5
City-owned stormwater
conveyance systems
at facilities
Pollution Prevention
Teams under
supervision of

22 The letters in the left hand column of this table reference the associated table of BMPS for the Pollution Prevention and Good
Housekeeping for Municipal Operations in the City’s NPDES Permit NCS000249. This table starts on page 14 of the permit.

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Table 7-7: BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations 22
BMP Measurable Goals Frequency Responsible
Position
program shall include maintenance
activities and procedures aimed at
preventing or reducing pollutants
generated from municipal facilities and
operations.
facility
Superintendent(s)
Other City-owned
stormwater
conveyance systems
(e.g. associated with
streets & parks)
Stormwater
Maintenance
Supervisor
(c) Site Pollution
Prevention Plans
for municipal
facilities.
Maintain and implement Site Pollution
Prevention Plans for municipal facilities
owned and operated by the permittee that
have been determined by the permittee to
have significant potential for generating
polluted stormwater runoff that has the
goal of preventing or reducing pollutant
runoff.
Ongoing
Pollution Prevention
Teams with
technical assistance
from Water Quality
Specialist
(Investigations and
Inspections)
(d) Spill Response
Procedures for
municipal
facilities and
operations.
Maintain spill response procedures for
municipal facilities and operations
owned and operated by the permittee
that have been determined by the
permittee to have significant potential
for generating polluted stormwater
runoff.
Facility spill response
procedures are
included in SPPPs
SPPPs reviewed by
Water Quality
Specialist
(Investigations and
Inspections)
Spill procedures in
place for sewage
discharges from City
and County collection
systems.
City:
Superintendent,
Water and Sewer
Maintenance;
County: Utility
Division Manager
(e) Prevent or
Minimize
Contamination of
Stormwater
Runoff from all
areas used for
Vehicle and
Equipment
Cleaning
Describe measures that prevent or
minimize contamination of the
stormwater runoff from all areas used
for vehicle and equipment cleaning,
including fire stations that have more
than three fire trucks and ambulances.
Perform all cleaning operations indoors,
cover the cleaning operations, ensure
wash water drains to the sanitary sewer
system, collect wash water and
stormwater run-on from the cleaning
area and provide treatment or recycling,
City fleet vehicles
(cars and light trucks)
are directed to
commercial car wash
facilities under
contract to the City.
Fleet Management
Most city emergency
vehicles are washed
where wash water can
be directed to the
sanitary sewer or to
vegetated areas.
Water Quality
Specialist
(Investigations and
Inspections)

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Table 7-7: BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations 22
BMP Measurable Goals Frequency Responsible
Position
or other equivalent measures. If
sanitary sewer is not available to the
facility and cleaning operations take
place outdoors, wash water shall drain
to an SCM for treatment, or else the
cleaning operations shall take place on
or drain directly to grassed or graveled
areas to prevent point source
discharges of the wash water into the
storm drains or surface waters.

Where cleaning operations cannot be
performed as described above and
when operations are performed in the
vicinity of a storm drainage collection
system, the drain is to be covered with
a portable drain cover during cleaning
activities. Any excess standing water
shall be removed and properly handled
prior to removing the drain cover.

Facilities that have three or fewer fire
trucks and ambulances should attempt
to comply with the above requirements;
however, those that cannot comply with
these requirements due to existing
limitations shall incorporate structural
measures during facility renovation to
the extent practicable.
During renovation of
Fire Stations 1 & 3,
rain gardens were
constructed for
treating wash water
General Services
Project Manager
Cleaning of heavy
trucks and heavy
equipment takes place
at constructed wash
facilities which are
covered under NPDES
industrial stormwater
permits
Industrial Permittee,
see
Appendix J
(f) Streets, roads,
and public
parking lots
maintenance
The permittee shall implement BMPs to
reduce polluted stormwater runoff from
municipally-owned streets, roads, and
public parking lots within the corporate
limits.
Completed
(review and update
annually)
Pollution Prevention
Coordinator
(g) Inspection and
Maintenance
(I&M) for
The permittee shall maintain and
implement an inspection and
maintenance program for stormwater
Field assessment of
City owned SCMs:
ongoing
Stormwater
Development
Review Manager

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Table 7-7: BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations 22
BMP Measurable Goals Frequency Responsible
Position
municipally-
owned or
maintained
stormwater
control measures
(SCMs) and the
storm sewer
system.
control measures (SCMs) owned and
operated by the municipality and the
municipal storm sewer system
(including catch basins, the conveyance
system, and SCMs).

Conduct routine
maintenance required
by the Stormwater
Development Review
field assessment
Department
responsible for the
SCM
Inspection of the
municipal stormwater
system
Stormwater
Maintenance
Supervisor &
Stormwater
Infrastructure
Manager
Maintenance of the
municipal stormwater
system
Stormwater
Maintenance
Supervisor
(h) Staff training Maintain and implement a training plan
that indicates when, how often, and
who is required to be trained and what
they are to be trained on.
Pollution Prevention
Coordinator

7.6.1 Operation and Maintenance Program
The City of Durham will continue to implement an operation and maintenance programs for the municipal
stormwater system; for City streets, roads and parking lots; for municipal operations; and for municipal
facilities owned and operated by the City that the City has determined to have significant potential for
generating pollutants that are carried off by stormwater runoff. Operation and maintenance of the MS4 is
discussed below in section 7.7(h). Operation and maintenance of streets, roads, and parking lots is
addressed in section 7.7(g).
Facilities included in the inventory developed for section 7.7(c) are required to develop and maintain a site
Stormwater Pollution Prevention Plan (SPPP) under section 7.7(b). The potential for generating pollutants
and the specific pollutants of concern are site specific. Appropriate operation and maintenance depends
upon the site configuration, the pollutants that may be encountered and other factors. Many appropriate
maintenance activities will be identified in the SPPP, while others will result from site inspection identifying
need for maintenance or repair.

The operation and maintenance activities carried out have the ultimate goal of preventing or reducing
pollutant runoff

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7.6.2 Site Stormwater Pollution Prevention Plan (SPPP) for Municipal Facilities
The 32 facilities owned and operated by the City have been classified into special action, high, medium,low,
and lowest priority based on history of inspections by Stormwater Service’s Industrial Inspection Staff.
Special Action, high and medium priority facilities have significant potential for generating polluted runoff.
Priorities are reassessed on an ongoing basis.
SPPPs have been developed for all municipal industrial facilities that are subject to NPDES Industrial
Stormwater permitting. All other municipal facilities classified as Special Action and high priority have SPPPs
developed.
New or newly identified facilities will be inspected within 6 months. Based on the initial inspection each new
facility with be assessed regarding whether the facility has significant potential for generating polluted
runoff, and the facility will be categorized of inspection as appropriate. SPPPs will be completed for new or
newly identified facilities that have significant potential for generating polluted runoff. Simplified SPPPs will
be developed for facilities in the Lowest category.

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7.6.3 Inspection and Evaluation of Municipal Facilities
Inventory
The City maintains an Industrial Inspections relational database to track facilities, their status and priority,
inspection results, and correspondence, including notices and penalties. The database includes both
municipal and private facilities. It includes NPDES-permitted and non-regulated facilities. The database
includes supplemental information such as industrial facilities that are now closed, and industrial facilities
located in Durham County that are outside city limits. Data is regularly obtained from various sources to
update the database.
The database designates municipal facilities determined by the City to have significant potential for
generating pollutants that can contaminate runoff in various inspection priority categories: Special Action,
High,Medium, Low, and Lowest. Each priority level has a corresponding inspection frequency: quarterly,
thrice annually, twice annually, annually, and once per three years.
In 2014 the priority system for inspecting both private industrial facilities and city facilities was revised.
Category assignments are based on facility compliance history, the industrial inspector’s experience, and our
assessment of the facility’s risk of generating runoff pollutants.
The intent of this system, like the one it replaces, is to focus staff resources on facilities that need
assistance. As facilities develop a track record of self-inspection, compliance and self-management, the
facility will change to a category proving for less frequent inspections. Conversely, if staff turn-over or other
circumstances result in a decline in performance, the facility’s category will be changed to increase
inspection frequency. The revised system allows automation of inspection prioritization, and facilitates
distribution of inspection workload among several staff members to facilitate succession planning.
The Industrial Stormwater Inspections Standard Operating Procedures document covers both private and
municipal inspections. This manual will be updated to discuss the priority system and its implementation
within the Industrial Inspections database.
With the exception of Special Action, the municipal categories are separate from the private categories and
have different inspection frequencies. Generally speaking, municipal facilities are inspected more frequently
than private facilities.
Present categorization and inspection frequencies are provided in Table 7-8. The majority of the facilities
are assigned to the Medium and Lowest categories based on facility compliance history, experience and risk.
The range of categories shown in the table results in a system flexible enough to accommodate fluctuations
in risk and the need for increased or decreased inspection frequency, as well as providing appropriate
categories for new operations that may be different in risk.

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Table 7-8 Municipal facility inspection priority categories, with risk of stormwater pollution, inspection
frequency, and current number of facilities in category.
Category  Special Action High Priority Medium
Priority Low Priority Lowest
Priority
Risk of
Stormwater
Pollution
Highest High Medium Low Lowest
Inspection
Frequency Quarterly 3x per year 2x per year 1x per year 1x every 3
years
2019
classification
of facilities
1 0 13 1 17

A facility’s category may change over time based on fluctuations in risk and the need for increased or
decreased inspection frequency.

Inspection
The City maintains a relational database to record facility information, results of inspections, listings of
notices and enforcement activity, location information, etc. The database tracks inspection category, which
will be revised as the inspection history changes over time. The database automates generation of lists of
private and municipal facilities due for inspection to facilitate scheduling.
The City has six facilities with NPDES Industrial Stormwater permits. As required by permit, each facility has
a facility SPPP and facility Pollution Prevention Team. Water Quality inspectors and the Pollution Prevention
Coordinator provide initial training to the Pollution Prevent Team. The Pollution Prevention Team is
responsible for conducting inspections required in the permit and SPPP, and for maintaining and updating
the SPPP. The Water Quality inspectors conduct additional inspections of these NPDES permitted facilities
together with members of the team in accordance with the inspection priority system discussed below. The
Pollution Prevention Coordinator (Water Quality Unit) provides annual training on Pollution Prevention to
facility staff. The facility Pollution Prevention Team is responsible for identifying site specific issues,
including issues that may require more specific training. The facility Pollution Prevention Team is
responsible for making sure staff are trained on site specific issues, either by conducting that training
themselves, or by providing photos and other information so that the Pollution Prevention Team can cover
the issue together with the general training.
Non-NPDES municipal facilities are inspected by Water Quality inspectors. Routine inspection will be in
accordance with a priority system established based on experience inspecting these city facilities, including,
as applicable, reviewing availability and implementation of the Stormwater Pollution Prevention Plan;
monitoring results; and record keeping on training, self- inspections and subsequent follow-up actions.
The Industrial Stormwater Inspections Standard Operating Procedures provide guidance for conducting
inspection of both private facilities and municipal facilities. Inspections of municipal facilities are always
conducted with one or more members of the facility’s stormwater pollution prevention team. Inspections
focus on identification of stormwater pollution issues and development of strategies for preventing or
addressing compliance issues.
For municipal industrial activities, inspections routinely include review of pertinent documentation:
• Stormwater Pollution Prevention Plan
o Permit-required elements

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o Annual updates, changes, and amendments
• Qualitative and Quantitative Runoff Monitoring Data (for NPDES permitted activities)
• Annual employee training records
• Semi-annual self-inspection records
• Non-stormwater discharge and spill incident history
• Annual self-review of program effectiveness

Inspection reports, automatically generated by the Stormwater Inspections MS Access Database, are
routinely provided to facility personnel upon completion of inspections, along with site photographs and
compliance assistance. In addition to site inspection results, the inspectors routinely send e-mail or inter-
office correspondence to remind facility pollution prevention team leaders of monitoring schedules,
deadlines, reissued General permits, etc.
Facilities reported as non-compliant with stormwater rules or having foreseeable risk of stormwater pollution
that cannot be fully resolved during an inspection are all given a follow-up inspection to insure corrective or
preventative actions are taken.
Annual reports will focus on inspections conducted by the Stormwater inspections staff.
7.6.4 Spill Response Procedures for Municipal Facilities and Operations
The Stormwater & GIS Division maintains a list or certified clean-up contractors for spills that most often
involved discharges to surface waters. The City-County Local Emergency Planning Committee in coordination
with Durham City-County Emergency Management is in the process of developing a more comprehensive list
of contractor resources to cover a wider variety of environmental emergencies.
Each City of Durham municipal operation that has developed a SPPP has established site-specific BMPs to
address spill prevention, spill response, and spill kits. Spill kits generally contain a combination of granular
absorbent, oil-absorbent pads, and absorbent spill control booms. In addition to facility general use kits, spill
kits are located at the City’s two fueling islands. Heavy duty vehicles having hydraulic systems that are
operated by Solid Waste and Water Management also carry spill kits and have backup assistance for spill
containment. Heavy duty vehicles in Public Works General Services carry granular absorbent to capture
spills. For other mobile operations, the City’s HazMat trucks and fire trucks carry spill kits and the City’s
Stormwater Pollution Control Ordinance requires private wrecker trucks to carry spill kits.
The City and County each operate publicly owned sanitary sewer systems with the City of Durham.
Stormwater Services responds to requests for assistance on sanitary sewer overflows from for each of these
operators. Because the City is located along a ridgeline between two river basins, most streams are small,
third order or less. When there is a discharge to one of these streams it has been normal for the utility to
install a pump to remove contaminated water and return it to the collection system. Stormwater Services
uses field test kits for ammonia to detect sewage impacting clear water, allowing pumps to be placed to
capture much more contaminated water than is possible using visual indicators.
The City’s Water Management Department has been highly effective in reducing both the frequency of
sanitary sewer discharges and the total volume discharged.
7.6.5 Prevent or Minimize Contamination of Stormwater Runoff from all areas used for vehicle
and equipment cleaning
City cars and light duty trucks are brought to a third-party commercial car wash. For more demanding
cleaning, the City has two wash pits at the Public Works Operations Center, a bay at the Solid Waste Truck
Wash, and a bay for busses at the Durham Area Transit Authority maintenance center, and an indoor wash
area at the Parks and Recreation Operations and Maintenance facility.

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Emergency vehicles must stay close to their assigned service area to meet response time goals. The City
Fire Department continues to comply with the City’s MS4 NPDES permit rule governing the washing of
emergency vehicles. Stormwater & GIS Services and the Fire Department continue to investigate a
renovation plan to allow vehicle washing at all Fire Stations. Until all stations have been retrofitted (if
possible), emergency vehicles may be brought to Stations 1, 3, 4, 5, 6, 7, 13, 14, or 16 for washing.
Wastewater from vehicle washing at those stations is directed into engineered retention areas, grassed
areas, or loosely graveled areas.
7.6.6 Streets, roads, and public parking lot maintenance
The City is continuing to implement the BMPs it has identified. These include street sweeping; removal dead
animals from streets, roads and highways; litter pick up at keep road intersections, bus stop cleaning, and
litter clean-up in the downtown area through partial funding of Downtown Durham, Inc.’s Durham
Ambassadors program. It also includes efforts to address petroleum spills by having clean-up kits readily
available.
Operation and Maintenance (O&M) for city-owned BMPs and city-owned storm sewer system (including catch
basins, the conveyance system, and structural stormwater controls)
Inspection and maintenance responsibilities extend across several work units and several programs. Street
cleaning crews clean street gutters and catch basins tops. There are two maintenance crews with CATV
equipment and Vactor units, one generally dedicated to preventative maintenance and the other to
complaint response. A pole camera is also used to inspect pipes.
In a given year, Stormwater Services may supplement city resources by contracting for video inspection
services.
Catch basins commonly used in Durham have combination inlets and are ‘self-cleaning,’ meaning that they
do not have sumps designed to catch and retain material. Street cleaning removes material that collects on
the inlet grate. Vactor trucks are used to remove sediment that accumulates in pipes and other conveyance
structures.
Stormwater quality personnel inspect outfalls (most of which are private) and screen any dry weather flows
for pollutants.
Inspection of privately owned structural BMPs and inspection and maintenance of city-owned structural
BMPs are addressed in the Post-Construction section of the Stormwater Management Plan, Section 7.6.
7.6.7 Staff Training
Municipal employee training has evolved over many years. Initially, this focused on pollution prevention
training of staff at permitted and high-risk facilities. Initially training was conducted by the Industrial
inspector. Once facilities developed Stormwater Pollution Prevention Teams those teams were expected to
provide training to incoming team members.
The Pollution Prevention Coordinator is an experienced educator and trainer. The City maintains a library of
training videos to support this position in providing training on:
• General site pollution prevention
• Spill response and reporting
• Illicit discharge identification and reporting
The Pollution Prevention Coordinator uses video resources, PowerPoint presentations, handout and written
guidance materials to cover issues for a given audience. Training sessions include pre-training and post-
training quizzes to document learning. Once a workgroup attains proficiency on pre-training quizzes, training
frequency can be modified to every other year.

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A self-paced presentation has been developed for orientation of new employees, with quizzes to document
learning.
The Pollution Prevention Coordinator maintains an inventory of work groups and contract operators
scheduled to be trained and the specific areas to cover in training. The Pollution Prevention Coordinator also
maintains records indicating generally the topics covered in each training session, sign-in sheets, and copies
of pre-training quiz and post-training quizzes.
The Pollution Prevention Coordinator began conducting annual training for designated work groups in FY
2013-2014. A goal of 80% correct answers on testing demonstrates adequate knowledge. Table 7-9
summarizes the overall effectiveness of the training through most of FY2015-16.
Table 7-9 Overall Results of Staff Testing
Fiscal Year Percentage of Work Groups
Scoring 80% or Higher
2013-2014 0%
2014-2015 48%
2015-2016 78%
2016-2017 100%
2017-2018 93%

Training is scheduled around availability of each work group within a fiscal year rather than on a fixed
schedule. Work groups designated as High Priority will be trained at least once each fiscal year. Work groups
designated as Medium and Low Priority will be trained every two years, unless a condition is noted (informal
observation, formal inspection, or otherwise) that warrants additional training. Group designations will be
determined by the nature of the work that is done by the group and by the scores on pre- and post-tests
given during the group’s most recent training. If a specific group does not answer at least 80% of pre- and
post-test questions correctly, they will be flagged for annual training. New employee training in each group
will continue to happen on a rolling basis as new employees are hired.
City facilities with NPDES permits have pollution prevention teams. Identification of common or reoccurring
issues by the facility’s Pollution Prevention Team may indicate the need for training on specific topics. The
Pollution Prevention Team is expected to conduct this training or else to provide photos and other
information to the Pollution Prevention Coordinator so that it can be covered in annual or biennial training.
7.6.8 Facilities
Typical municipal activities, operations, and facilities are outlined in Appendix J. This document provides an
inventory of facilities and operations owned and/or operated by the City of Durham with the potential for
generating polluted stormwater runoff. Appendix J lists the five City operated facilities with NPDES Industrial
Stormwater Permits and a sixth privately operated facility on City property with permit coverage. Additional
priority facilities have developed and are implementing Stormwater Pollution Prevention Plans (SPPPs).

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7.7 Pollution Prevention and Good Housekeeping for Municipal Operations

The objectives for this measure are to:
• Prevent or reduce stormwater pollution from municipal operations and municipal facilities.
• Train employees on how to incorporate Pollution Prevention and Good Housekeeping techniques into municipal
operations.
Pollution prevention and good housekeeping programs are an important factor in the improvement of
stormwater quality. Municipal maintenance facilities can be significant sources of pollution if not managed
properly. Other municipal activities, such as waste collection, offer significant opportunities to prevent
pollution and recycle materials. Recycling, household hazardous waste and oil collection, and street
sweeping are examples of some of the procedures that promote proper handling of materials to help prevent
pollution.
The table below summarizes the BMPs to be implemented and maintained during the remainder of the
permit under the pollution prevention and good housekeeping for municipal operations measure. Text
sections that follow the table further explain the BMPs intended to meet this requirement.
Table 7-7: BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations 23
BMP Measurable Goals Frequency Responsible
Position
(i) Inventory of
municipal
facilities and
operations
Maintain an inventory of municipal
facilities and operations owned and
operated by the permittee that have
been determined by the permittee to
have significant potential for generating
polluted stormwater runoff. Also
maintain an inventory of municipally-
owned structural SCMs.
Municipal facilities
inventory: ongoing
Water Quality
Specialist
(Investigations and
Inspections)
Municipally- owned
SCMs inventory:
ongoing
SCM Maintenance
Program
Coordinator
SCM inventory, see section 7.6
(j) Inspection and
maintenance
program for
municipal
facilities and
operations
Implement an inspection and
maintenance program for facilities and
operations owned and operated by the
permittee for facilities and operations
owned and operated by the City of
Durham for potential sources of
polluted runoff, including stormwater
controls and conveyance systems. The
inspection program shall evaluate
pollutant sources, document
deficiencies, plan corrective actions,
implement appropriate controls, and
document the accomplishment of
corrective actions. The maintenance
Facility inspections:
ongoing
Water Quality
Specialist
(Investigations and
Inspections)
Facility Maintenance:
ongoing
Pollution Prevention
Teams under
supervision of
facility
Superintendent(s)
SCM Inspection and Maintenance, see
section 7.6.5
City-owned stormwater
conveyance systems
at facilities
Pollution Prevention
Teams under
supervision of

23 The letters in the left hand column of this table reference the associated table of BMPS for the Pollution Prevention and Good
Housekeeping for Municipal Operations in the City’s NPDES Permit NCS000249. This table starts on page 14 of the permit.

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Table 7-7: BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations 23
BMP Measurable Goals Frequency Responsible
Position
program shall include maintenance
activities and procedures aimed at
preventing or reducing pollutants
generated from municipal facilities and
operations.
facility
Superintendent(s)
Other City-owned
stormwater
conveyance systems
(e.g. associated with
streets & parks)
Stormwater
Maintenance
Supervisor
(k) Site Pollution
Prevention Plans
for municipal
facilities.
Maintain and implement Site Pollution
Prevention Plans for municipal facilities
owned and operated by the permittee that
have been determined by the permittee to
have significant potential for generating
polluted stormwater runoff that has the
goal of preventing or reducing pollutant
runoff.
Ongoing
Pollution Prevention
Teams with
technical assistance
from Water Quality
Specialist
(Investigations and
Inspections)
(l) Spill Response
Procedures for
municipal
facilities and
operations.
Maintain spill response procedures for
municipal facilities and operations
owned and operated by the permittee
that have been determined by the
permittee to have significant potential
for generating polluted stormwater
runoff.
Facility spill response
procedures are
included in SPPPs
SPPPs reviewed by
Water Quality
Specialist
(Investigations and
Inspections)
Spill procedures in
place for sewage
discharges from City
and County collection
systems.
City:
Superintendent,
Water and Sewer
Maintenance;
County: Utility
Division Manager
(m) Prevent or
Minimize
Contamination of
Stormwater
Runoff from all
areas used for
Vehicle and
Equipment
Cleaning
Describe measures that prevent or
minimize contamination of the
stormwater runoff from all areas used
for vehicle and equipment cleaning,
including fire stations that have more
than three fire trucks and ambulances.
Perform all cleaning operations indoors,
cover the cleaning operations, ensure
wash water drains to the sanitary sewer
system, collect wash water and
stormwater run-on from the cleaning
area and provide treatment or recycling,
City fleet vehicles
(cars and light trucks)
are directed to
commercial car wash
facilities under
contract to the City.
Fleet Management
Most city emergency
vehicles are washed
where wash water can
be directed to the
sanitary sewer or to
vegetated areas.
Water Quality
Specialist
(Investigations and
Inspections)

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Table 7-7: BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations 23
BMP Measurable Goals Frequency Responsible
Position
or other equivalent measures. If
sanitary sewer is not available to the
facility and cleaning operations take
place outdoors, wash water shall drain
to an SCM for treatment, or else the
cleaning operations shall take place on
or drain directly to grassed or graveled
areas to prevent point source
discharges of the wash water into the
storm drains or surface waters.

Where cleaning operations cannot be
performed as described above and
when operations are performed in the
vicinity of a storm drainage collection
system, the drain is to be covered with
a portable drain cover during cleaning
activities. Any excess standing water
shall be removed and properly handled
prior to removing the drain cover.

Facilities that have three or fewer fire
trucks and ambulances should attempt
to comply with the above requirements;
however, those that cannot comply with
these requirements due to existing
limitations shall incorporate structural
measures during facility renovation to
the extent practicable.
During renovation of
Fire Stations 1 & 3,
rain gardens were
constructed for
treating wash water
General Services
Project Manager
Cleaning of heavy
trucks and heavy
equipment takes place
at constructed wash
facilities which are
covered under NPDES
industrial stormwater
permits
Industrial Permittee,
see
Appendix J
(n) Streets, roads,
and public
parking lots
maintenance
The permittee shall implement BMPs to
reduce polluted stormwater runoff from
municipally-owned streets, roads, and
public parking lots within the corporate
limits.
Completed
(review and update
annually)
Pollution Prevention
Coordinator
(o) Inspection and
Maintenance
(I&M) for
The permittee shall maintain and
implement an inspection and
maintenance program for stormwater
Field assessment of
City owned SCMs:
ongoing
Stormwater
Development
Review Manager

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Table 7-7: BMP Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations 23
BMP Measurable Goals Frequency Responsible
Position
municipally-
owned or
maintained
stormwater
control measures
(SCMs) and the
storm sewer
system.
control measures (SCMs) owned and
operated by the municipality and the
municipal storm sewer system
(including catch basins, the conveyance
system, and SCMs).

Conduct routine
maintenance required
by the Stormwater
Development Review
field assessment
Department
responsible for the
SCM
Inspection of the
municipal stormwater
system
Stormwater
Maintenance
Supervisor &
Stormwater
Infrastructure
Manager
Maintenance of the
municipal stormwater
system
Stormwater
Maintenance
Supervisor
(p) Staff training Maintain and implement a training plan
that indicates when, how often, and
who is required to be trained and what
they are to be trained on.
Pollution Prevention
Coordinator

7.7.1 Operation and Maintenance Program
The City of Durham will continue to implement an operation and maintenance programs for the municipal
stormwater system; for City streets, roads and parking lots; for municipal operations; and for municipal
facilities owned and operated by the City that the City has determined to have significant potential for
generating pollutants that are carried off by stormwater runoff. Operation and maintenance of the MS4 is
discussed below in section 7.7(h). Operation and maintenance of streets, roads, and parking lots is
addressed in section 7.7(g).
Facilities included in the inventory developed for section 7.7(c) are required to develop and maintain a site
Stormwater Pollution Prevention Plan (SPPP) under section 7.7(b). The potential for generating pollutants
and the specific pollutants of concern are site specific. Appropriate operation and maintenance depends
upon the site configuration, the pollutants that may be encountered and other factors. Many appropriate
maintenance activities will be identified in the SPPP, while others will result from site inspection identifying
need for maintenance or repair.

The operation and maintenance activities carried out have the ultimate goal of preventing or reducing
pollutant runoff

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7.7.2 Site Stormwater Pollution Prevention Plan (SPPP) for Municipal Facilities
The 32 facilities owned and operated by the City have been classified into special action, high, medium,low,
and lowest priority based on history of inspections by Stormwater Service’s Industrial Inspection Staff.
Special Action, high and medium priority facilities have significant potential for generating polluted runoff.
Priorities are reassessed on an ongoing basis.
SPPPs have been developed for all municipal industrial facilities that are subject to NPDES Industrial
Stormwater permitting. All other municipal facilities classified as Special Action and high priority have SPPPs
developed.
New or newly identified facilities will be inspected within 6 months. Based on the initial inspection each new
facility with be assessed regarding whether the facility has significant potential for generating polluted
runoff, and the facility will be categorized of inspection as appropriate. SPPPs will be completed for new or
newly identified facilities that have significant potential for generating polluted runoff. Simplified SPPPs will
be developed for facilities in the Lowest category.
7.7.3 Inspection and Evaluation of Municipal Facilities
Inventory
The City maintains an Industrial Inspections relational database to track facilities, their status and priority,
inspection results, and correspondence, including notices and penalties. The database includes both
municipal and private facilities. It includes NPDES-permitted and non-regulated facilities. The database
includes supplemental information such as industrial facilities that are now closed, and industrial facilities
located in Durham County that are outside city limits. Data is regularly obtained from various sources to
update the database.
The database designates municipal facilities determined by the City to have significant potential for
generating pollutants that can contaminate runoff in various inspection priority categories: Special Action,
High,Medium, Low, and Lowest. Each priority level has a corresponding inspection frequency: quarterly,
thrice annually, twice annually, annually, and once per three years.
In 2014 the priority system for inspecting both private industrial facilities and city facilities was revised.
Category assignments are based on facility compliance history, the industrial inspector’s experience, and our
assessment of the facility’s risk of generating runoff pollutants.
The intent of this system, like the one it replaces, is to focus staff resources on facilities that need
assistance. As facilities develop a track record of self-inspection, compliance and self-management, the
facility will change to a category proving for less frequent inspections. Conversely, if staff turn-over or other
circumstances result in a decline in performance, the facility’s category will be changed to increase
inspection frequency. The revised system allows automation of inspection prioritization, and facilitates
distribution of inspection workload among several staff members to facilitate succession planning.
The Industrial Stormwater Inspections Standard Operating Procedures document covers both private and
municipal inspections. This manual will be updated to discuss the priority system and its implementation
within the Industrial Inspections database.
With the exception of Special Action, the municipal categories are separate from the private categories and
have different inspection frequencies. Generally speaking, municipal facilities are inspected more frequently
than private facilities.
Present categorization and inspection frequencies are provided in Table 7-8. The majority of the facilities
are assigned to the Medium and Lowest categories based on facility compliance history, experience and risk.
The range of categories shown in the table results in a system flexible enough to accommodate fluctuations
in risk and the need for increased or decreased inspection frequency, as well as providing appropriate
categories for new operations that may be different in risk.

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7-126

Table 7-8 Municipal facility inspection priority categories, with risk of stormwater pollution, inspection
frequency, and current number of facilities in category.
Category  Special Action High Priority Medium
Priority Low Priority Lowest
Priority
Risk of
Stormwater
Pollution
Highest High Medium Low Lowest
Inspection
Frequency Quarterly 3x per year 2x per year 1x per year 1x every 3
years
2019
classification
of facilities
1 0 13 1 17

A facility’s category may change over time based on fluctuations in risk and the need for increased or
decreased inspection frequency.

Inspection
The City maintains a relational database to record facility information, results of inspections, listings of
notices and enforcement activity, location information, etc. The database tracks inspection category, which
will be revised as the inspection history changes over time. The database automates generation of lists of
private and municipal facilities due for inspection to facilitate scheduling.
The City has six facilities with NPDES Industrial Stormwater permits. As required by permit, each facility has
a facility SPPP and facility Pollution Prevention Team. Water Quality inspectors and the Pollution Prevention
Coordinator provide initial training to the Pollution Prevent Team. The Pollution Prevention Team is
responsible for conducting inspections required in the permit and SPPP, and for maintaining and updating
the SPPP. The Water Quality inspectors conduct additional inspections of these NPDES permitted facilities
together with members of the team in accordance with the inspection priority system discussed below. The
Pollution Prevention Coordinator (Water Quality Unit) provides annual training on Pollution Prevention to
facility staff. The facility Pollution Prevention Team is responsible for identifying site specific issues,
including issues that may require more specific training. The facility Pollution Prevention Team is
responsible for making sure staff are trained on site specific issues, either by conducting that training
themselves, or by providing photos and other information so that the Pollution Prevention Team can cover
the issue together with the general training.
Non-NPDES municipal facilities are inspected by Water Quality inspectors. Routine inspection will be in
accordance with a priority system established based on experience inspecting these city facilities, including,
as applicable, reviewing availability and implementation of the Stormwater Pollution Prevention Plan;
monitoring results; and record keeping on training, self- inspections and subsequent follow-up actions.
The Industrial Stormwater Inspections Standard Operating Procedures provide guidance for conducting
inspection of both private facilities and municipal facilities. Inspections of municipal facilities are always
conducted with one or more members of the facility’s stormwater pollution prevention team. Inspections
focus on identification of stormwater pollution issues and development of strategies for preventing or
addressing compliance issues.
For municipal industrial activities, inspections routinely include review of pertinent documentation:
• Stormwater Pollution Prevention Plan
o Permit-required elements

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o Annual updates, changes, and amendments
• Qualitative and Quantitative Runoff Monitoring Data (for NPDES permitted activities)
• Annual employee training records
• Semi-annual self-inspection records
• Non-stormwater discharge and spill incident history
• Annual self-review of program effectiveness

Inspection reports, automatically generated by the Stormwater Inspections MS Access Database, are
routinely provided to facility personnel upon completion of inspections, along with site photographs and
compliance assistance. In addition to site inspection results, the inspectors routinely send e-mail or inter-
office correspondence to remind facility pollution prevention team leaders of monitoring schedules,
deadlines, reissued General permits, etc.
Facilities reported as non-compliant with stormwater rules or having foreseeable risk of stormwater pollution
that cannot be fully resolved during an inspection are all given a follow-up inspection to insure corrective or
preventative actions are taken.
Annual reports will focus on inspections conducted by the Stormwater inspections staff.

7.7.4 Spill Response Procedures for Municipal Facilities and Operations
The Stormwater & GIS Division maintains a list or certified clean-up contractors for spills that most often
involved discharges to surface waters. The City-County Local Emergency Planning Committee in coordination
with Durham City-County Emergency Management is in the process of developing a more comprehensive list
of contractor resources to cover a wider variety of environmental emergencies.
Each City of Durham municipal operation that has developed a SPPP has established site-specific BMPs to
address spill prevention, spill response, and spill kits. Spill kits generally contain a combination of granular
absorbent, oil-absorbent pads, and absorbent spill control booms. In addition to facility general use kits, spill
kits are located at the City’s two fueling islands. Heavy duty vehicles having hydraulic systems that are
operated by Solid Waste and Water Management also carry spill kits and have backup assistance for spill
containment. Heavy duty vehicles in Public Works General Services carry granular absorbent to capture
spills. For other mobile operations, the City’s HazMat trucks and fire trucks carry spill kits and the City’s
Stormwater Pollution Control Ordinance requires private wrecker trucks to carry spill kits.
The City and County each operate publicly owned sanitary sewer systems with the City of Durham.
Stormwater Services responds to requests for assistance on sanitary sewer overflows from for each of these
operators. Because the City is located along a ridgeline between two river basins, most streams are small,
third order or less. When there is a discharge to one of these streams it has been normal for the utility to
install a pump to remove contaminated water and return it to the collection system. Stormwater Services
uses field test kits for ammonia to detect sewage impacting clear water, allowing pumps to be placed to
capture much more contaminated water than is possible using visual indicators.
The City’s Water Management Department has been highly effective in reducing both the frequency of
sanitary sewer discharges and the total volume discharged.

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7.7.5 Prevent or Minimize Contamination of Stormwater Runoff from all areas used for vehicle
and equipment cleaning
City cars and light duty trucks are brought to a third-party commercial car wash. For more demanding
cleaning, the City has two wash pits at the Public Works Operations Center, a bay at the Solid Waste Truck
Wash, and a bay for busses at the Durham Area Transit Authority maintenance center, and an indoor wash
area at the Parks and Recreation Operations and Maintenance facility.
Emergency vehicles must stay close to their assigned service area to meet response time goals. The City
Fire Department continues to comply with the City’s MS4 NPDES permit rule governing the washing of
emergency vehicles. Stormwater & GIS Services and the Fire Department continue to investigate a
renovation plan to allow vehicle washing at all Fire Stations. Until all stations have been retrofitted (if
possible), emergency vehicles may be brought to Stations 1, 3, 4, 5, 6, 7, 13, 14, or 16 for washing.
Wastewater from vehicle washing at those stations is directed into engineered retention areas, grassed
areas, or loosely graveled areas.
7.7.6 Streets, roads, and public parking lot maintenance
The City is continuing to implement the BMPs it has identified. These include street sweeping; removal dead
animals from streets, roads and highways; litter pick up at keep road intersections, bus stop cleaning, and
litter clean-up in the downtown area through partial funding of Downtown Durham, Inc.’s Durham
Ambassadors program. It also includes efforts to address petroleum spills by having clean-up kits readily
available.
Operation and Maintenance (O&M) for city-owned BMPs and city-owned storm sewer system (including catch
basins, the conveyance system, and structural stormwater controls)
Inspection and maintenance responsibilities extend across several work units and several programs. Street
cleaning crews clean street gutters and catch basins tops. There are two maintenance crews with CATV
equipment and Vactor units, one generally dedicated to preventative maintenance and the other to
complaint response. A pole camera is also used to inspect pipes.
In a given year, Stormwater Services may supplement city resources by contracting for video inspection
services.
Catch basins commonly used in Durham have combination inlets and are ‘self-cleaning,’ meaning that they
do not have sumps designed to catch and retain material. Street cleaning removes material that collects on
the inlet grate. Vactor trucks are used to remove sediment that accumulates in pipes and other conveyance
structures.
Stormwater quality personnel inspect outfalls (most of which are private) and screen any dry weather flows
for pollutants.
Inspection of privately owned structural BMPs and inspection and maintenance of city-owned structural
BMPs are addressed in the Post-Construction section of the Stormwater Management Plan, Section 7.6.
7.7.7 Staff Training
Municipal employee training has evolved over many years. Initially, this focused on pollution prevention
training of staff at permitted and high-risk facilities. Initially training was conducted by the Industrial
inspector. Once facilities developed Stormwater Pollution Prevention Teams those teams were expected to
provide training to incoming team members.
The Pollution Prevention Coordinator is an experienced educator and trainer. The City maintains a library of
training videos to support this position in providing training on:
• General site pollution prevention
• Spill response and reporting

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• Illicit discharge identification and reporting
The Pollution Prevention Coordinator uses video resources, PowerPoint presentations, handout and written
guidance materials to cover issues for a given audience. Training sessions include pre-training and post-
training quizzes to document learning. Once a workgroup attains proficiency on pre-training quizzes, training
frequency can be modified to every other year.
A self-paced presentation has been developed for orientation of new employees, with quizzes to document
learning.
The Pollution Prevention Coordinator maintains an inventory of work groups and contract operators
scheduled to be trained and the specific areas to cover in training. The Pollution Prevention Coordinator also
maintains records indicating generally the topics covered in each training session, sign-in sheets, and copies
of pre-training quiz and post-training quizzes.
The Pollution Prevention Coordinator began conducting annual training for designated work groups in FY
2013-2014. A goal of 80% correct answers on testing demonstrates adequate knowledge. Table 7-9
summarizes the overall effectiveness of the training through most of FY2015-16.
Table 7-9 Overall Results of Staff Testing
Fiscal Year Percentage of Work Groups
Scoring 80% or Higher
2013-2014 0%
2014-2015 48%
2015-2016 78%
2016-2017 100%
2017-2018 93%

Training is scheduled around availability of each work group within a fiscal year rather than on a fixed
schedule. Work groups designated as High Priority will be trained at least once each fiscal year. Work groups
designated as Medium and Low Priority will be trained every two years, unless a condition is noted (informal
observation, formal inspection, or otherwise) that warrants additional training. Group designations will be
determined by the nature of the work that is done by the group and by the scores on pre- and post-tests
given during the group’s most recent training. If a specific group does not answer at least 80% of pre- and
post-test questions correctly, they will be flagged for annual training. New employee training in each group
will continue to happen on a rolling basis as new employees are hired.
City facilities with NPDES permits have pollution prevention teams. Identification of common or reoccurring
issues by the facility’s Pollution Prevention Team may indicate the need for training on specific topics. The
Pollution Prevention Team is expected to conduct this training or else to provide photos and other
information to the Pollution Prevention Coordinator so that it can be covered in annual or biennial training.
7.7.8 Facilities
Typical municipal activities, operations, and facilities are outlined in Appendix J. This document provides an
inventory of facilities and operations owned and/or operated by the City of Durham with the potential for
generating polluted stormwater runoff. Appendix J lists the five City operated facilities with NPDES Industrial
Stormwater Permits and a sixth privately operated facility on City property with permit coverage. Additional
priority facilities have developed and are implementing Stormwater Pollution Prevention Plans (SPPPs).

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7.8 Program to Monitor and Control Pollutants to Municipal Systems
The target facilities of the program designed to monitor and control pollutants in storm water discharges to
the permittee’s MS4 are: hazardous waste treatment, storage, disposal facilities; recovery facilities;
industrial facilities subject to Section 313 of Title III of the Superfund Amendments and Reauthorization Act
of 1986 (SARA); and industrial facilities that the Permittee determines are contributing or have a potential to
contribute a substantial pollutant load to the municipal storm sewer system.
The City of Durham has developed and implemented an industrial facilities inspections program during
previous permit terms. The City places particular emphasis on inspecting facilities that report releases
(Section 313 of Title III of SARA) and that do not have NPDES permits. The City typically also identifies a
ubiquitous business sector on which effort is focused. These have included auto salvage yards and facilities
with numerous inoperable vehicles, mobile auto maintenance operations, and vehicle service facilities.
The City’s Stormwater Pollution Control Ordinance (Durham City Code Chapter 70, Article V) mandates
certain pollution prevention practices. For example, Section 70-515 includes pollution prevention
requirements for automotive activities, requiring vehicle maintenance to take place in a covered bay, and
automotive fluids stored outside to be to have secondary containment and to be stored under a covered
area. Section 70-516 requires facilities that have more than ten junk, salvage or unlicensed vehicles to
develop and implement a SPPP. Section 70-517 provides requirements for storage of hazardous
substances.
The table below summarizes the BMPs to be implemented and maintained during the remainder of the
permit to meet requirements to monitor and control pollutants entering the municipal system.

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Table 7-10: BMP Summary Table for Monitoring and Control of Pollutants Entering the MS424
BMP Measurable Goals Frequency Responsible
Position
(a) Maintain an
Inventory of
Industrial
Facilities
Maintain a database inventory of permitted
hazardous waste treatment, disposal and
recovery facilities, industrial facilities that are
subject to Section 313 of Title II of the Superfund
Amendments and Reauthorization Act of 1986
(SARA), and industrial facilities identified with an
industrial activity permitted under 40 CFR
122.26 that discharge storm water to the
permittee’s MS4.
See text
below for
inventory
maintenance
Water Quality
Specialist
(investigations
and inspections)
(b) Inspection
Program
Review and revise inspection priorities.
Periodically review and revise inspection
procedures.
Monthly to
Annually,
depending
upon
inspection
results
Water Quality
Specialist
(investigations
and inspections)
(c) Evaluate
Industrial
Facilities
discharging
stormwater to
the City’s MS4
For permitted facilities, the municipality shall
establish procedures for reporting deficiencies
and non-compliance to the permitting agency.
Where compliance with an existing industrial
stormwater permit does not result in adequate
control of pollutants to the MS4, the municipality
will recommend and document the need for
permit modifications or additions to the permit
issuing authority.
See Table 7-
12 for
inspection
priorities
Industrial
Inspections staff The permittee is required to evaluate control
measures implemented at permitted hazardous
waste treatment, disposal, and recovery facilities,
industrial facilities that are subject to Section
313 of Title II of SARA (TRI), industrial facilities
identified with an industrial activity permitted to
discharge storm water to the permittee’s MS4, or
as identified as an illicit discharge under the
IDDE program.

24 The letters in the left hand column of this table reference the associated table of BMPS for the Program to Monitor and Evaluate Storm Water
Discharges to Municipal Systems in the City’s NPDES Permit NCS000249. This table starts on page 16 of the permit.

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Table 7-10: BMP Summary Table for Monitoring and Control of Pollutants Entering the MS424
BMP Measurable Goals Frequency Responsible
Position
For the purposes of this permit, industrial
activities shall mean all permitted industrial
activities as defined in 40 CFR 122.26. For the
purpose of this permit, the Permittee is
authorized to inspect the permitted hazardous
waste treatment, disposal, and recovery facilities
as an authorized representative of the Director.

7.8.1 Inventory of Industrial Sites
The Inspections Program maintains a Microsoft Access database to store general information, inspection
results, compliance status, and ordinance enforcement details for each private and municipal industrial
facility within the City limits. The database is used to track and schedule inspections. This database has
been regularly revised and updated to improve utility, and includes coordinate data collected in the field with
handheld GPS devices or determined using aerial imagery and GIS for more than 90% of the facilities.
7.8.2 Inventory Maintenance
The City’s inventory of industrial sites is updated using:
• Semi-annual queries of EPA’s Toxic Release Inventory (July and October, corresponding with the EPA’s update
schedule) to identify facilities subject to Section 313 of SARA Title III;
• Quarterly lists of all NPDES permitted facilities in Durham County obtained from the Stormwater Permitting Unit
at the NC Division of Energy, Minerals and Land Resources;
• Quarterly queries of EPA’s RCRAInfo search tool to identify permitted hazardous waste treatment, disposal,
storage, and recovery facilities; and
• Routine queries of the City of Durham Stormwater Services Water Quality Investigation database (IDDE
program records) to identify facilities associated with illicit discharges.
As of 2018, there were no TRD facilities located within City limits.
Table 7.11 Inventory of Industrial and Light Industrial Facilities
As of October 2018.
Type of Facility Number inside City
Limits*
Permitted hazardous waste treatment, disposal and
recovery facilities 0
Facilities that reported releases under section 313 of Title III
of the Superfund Amendments and Reauthorization Act of
1986 (SARA) [toxic release inventory, (TRI)]
7
Facilities with an industrial activity permitted in accordance
with 40 CFR 122.26 to discharge stormwater to the
permittee’s MS4
32
Facilities with No Exposure Certification 23

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Non-NPDES permitted facilities with industrial or light
industrial activities similar to those permitted under 40 CFR
122.26
393
Totals 448**
*Our database additionally tracks a number of NPDES Stormwater-permitted and non-permitted industrial
facilities outside of the City Limits.
** Adding this column down results in a sum of 455. However, of the 7 TRI-listed facilities, 5
additionally have NPDES Stormwater Permits, 1 has a No Exposure Certification, and 1 is counted
as Non-NPDES. To display the accurate sum, we have subtracted those 7 double-counted facilities
to arrive at an accurate total of 448.
7.8.3 Inspection Procedures
The City follows written procedures in conducting the inspection program. As the inspection program
continues to evolve, the City will update and maintain these procedures based on experience.
To guide inspection of the expanded inventory the city has been refining a priority system to guide
inspections. Under the current scheme created in 2014, facility inspection priority and frequency is based on
risk and compliance history. Every facility is assigned and inspected according to a priority level reflecting a
combination of risk of stormwater pollution and history of compliance with stormwater regulations.
Facilities found to be in compliance on a routine inspection would qualify to be inspected less frequently,
while non-compliant facilities may qualify for more frequent inspection. Facilities that have not yet been
inspected and that are (or appear to be) engaged in automotive service and these have been assigned to the
medium priority. Over time, facilities with good compliance records will move to lower priority categories,
freeing up staff to conduct inspection of facilities that have not yet been inspected. The sorting that will
occur over time will focus available staff resources and guidance on those facilities that most need it.
Compliance on a follow-up inspection does not change the facility priority level. While routine inspections are
comprehensive, follow-up inspections are used to track progress on a limited number of issues, to assess
the need for additional corrective action/enforcement, and to document compliance.
This system allows us to focus on those facilities most in need of oversight, corrective action, or both.
Private industrial and light industrial facilities are inspected according to the following hierarchy:
1. Facilities requiring follow-up inspection – corrective actions needed
2. Special Action Plan (SAP) – one facility designated for this extra attention
3. High Priority – high risk and/or recent history of non-compliance, annual inspection
Facilities reporting releases on the EPA TRI Facility Release Report and TSDFs remain high priority regardless
of compliance history
4. Medium Priority – lower risk, inspect biennially
5. Low Priority – lowest risk, inspect every 3 years
6. No Exposure – NCDEQ has issued No Exposure Certification, inspect every 5 years
7. No Inspection Needed – no storage of pollutants or pollutant-generating activities
A flow chart for the inspection priority scheme is provided in Figure 7-6. Additional discussion and details are
provided in the revised Inspections Program Standard Operation Procedures.
The stormwater inspections database tracks a facility’s priority rank and automatically assigns the proper
inspection frequency. Database reports that have been automated include one to generate a current listing
of facilities due for inspection based on priority, inspection frequency, and time since most recent

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inspection. Separate inspection-due reports may be generated for private facilities and for municipal
facilities.
Table 7-12 below summarizes the inspection frequency goal for each priority category. Facilities are
occasionally elevated or demoted in priority according to additional characteristics and observations made
by Stormwater Inspectors or supervising Water Quality Specialist. Annual report will typically include updated
versions of this table when there has been significant change.

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Table 7-12. Description of facility inspection priority levels, with 2018 category totals.
Category  Special
Action High Priority Medium
Priority Low Priority No Exposure No Inspection
Needed
Risk of
Stormwater
Pollution
Highest High Medium Low Lowest None
Inspection
Frequency
Goal
Quarterly 1x per year 1x per 2 years 1x per 3 years 1x per 5 years Not inspected
Number of
facilities1 0 67 176 91 19 95
1 As of October 2018
Figure 7-6. Inspections priority flowchart showing the inspection frequency and promotion/demotion of
facilities based on routine inspection results.

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7.9 Water Quality Assessment and Monitoring
This Water Quality Monitoring & Assessment Plan was prepared to comply with Part II, Section I of the City of
Durham’s National Pollution Discharge Elimination System (NPDES) Permit for stormwater discharges issued
October10, 2018. The objective of this section of the permit is to “evaluate the impacts of MS4 discharges
on water quality.” Additional requirements in the Water Quality Assessment and Monitoring Plan are as
follows:
Table 7-13: BMP Summary Table for Monitoring and Control of Pollutants Entering the MS425
BMP Measurable Goals Frequency Responsible
Position
(a) Water Quality
Assessment and
Monitoring Plan
Maintain a Water Quality Assessment and
Monitoring Plan. The Plan shall include a
schedule for implementing the proposed
assessment and monitoring activities.
Ongoing Water Quality
Manager
(b) Water Quality
Monitoring
Maintain and implement the Water Quality
Assessment and Monitoring Plan submitted to
DEMLR.
Ongoing
Water Quality
Specialist
(Assessment and
Monitoring)

Requirements to establish an assessment and monitoring program were included in the permit effective July
1, 2007. The subsequent permit effective March 1, 2013 included requirements to maintain and implement
the water quality assessment and monitoring plan. The current permit continues these requirements.
The current permit requirements logically follow the establishment of an assessment and monitoring
program, as described in the first permits. The subsequent permit placed additional emphasis on starting an
assessment and monitoring plan, and included specific timelines.
This Water Quality Assessment & Monitoring Plan connects the pollution prevention activities in the NPDES
permit to assessment and monitoring. Quality Assurance Project Plans (QAPPs), Standard Operating
Procedures (SOPs), and other internal guidance documents are used to document the details of the
program.
7.9.1 Assessments and Monitoring under Previous Permits
The City of Durham monitoring program has evolved since the 1990s. Per permit requirements, initial
monitoring was designed to generate pollutant loading rates by land use and to evaluate outfalls located
throughout the City. Subsequent monitoring has been designed toward characterizing stream conditions,
including storm events. Ad-hoc monitoring was performed until 2003. In 2003 a quarterly, fixed-interval
ambient chemistry monitoring program was implemented. In 2004 a monthly, fixed-interval ambient
chemistry monitoring program began. An unstructured monitoring program continued for benthic
macroinvertebrates until approximately 2007. Special studies have been conducted to support TMDL
development when needed. These include the bacteria source tracking project [2003-2004] and intensive
fecal coliform monitoring. Wet weather monitoring of Stormwater Control Measures (SCMs) was performed
cooperatively with local universities.
Initial monitoring for pollutant loading rates was reported to NC Department of Environmental Quality
(formerly the Department of Environment and Natural Resources). As the monitoring program began to
evolve, qualitative assessments of chemistry and benthic macroinvertebrate monitoring data were

25 The letters in the left hand column of this table reference the associated table of BMPS for the Program to Monitor and Evaluate Storm Water
Discharges to Municipal Systems in the City’s NPDES Permit NCS000249. This table starts on page 16 of the permit.

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performed. Additional quantitative assessments have been performed in more recent years. As the
assessment methodology is modified, the monitoring to support the assessment may also be modified. All of
these changes are reflected in SOPs and QAPPs.
7.9.2 Assessment
Stormwater & GIS Services has performed several data evaluations and assessments in the past. These
have been reported in previous annual NPDES reports and summarized in the State of Our Streams report
since 2004. EPA guidance on data quality assessments suggests a review of the objectives and sampling
design and preliminary data review as the first two steps of a statistical data review (EPA 2006). At the
center of all data assessment and collection goals is a commitment to quality assurance. A review of
assessment and monitoring goals was conducted to determine if new goals have been identified. The
resulting program goals are as follows:
Core goals:
• to identify illicit discharges to area streams
• to identify pollution problem areas within the City
• to assess compliance with state water quality programs, including Total Maximum Daily Loads (TMDLs), water
quality standards, and nutrient management strategies
Supplemental goals:
• to identify overall trends to water quality
• to evaluate the performance of Stormwater Control Measures (SCMs)
• to determine potential pollution removal credits
• to assess the overall quality of streams within the City of Durham, and
• to evaluate the water quality impacts of urban stormwater on area streams.
The program goals have been separated into core and supplemental goals. Core goals have not changed
from past years; these goals have been assessed regularly since 2004. Other supplemental goals are
assessed depending on the resources available and priority. Therefore, these goals may not be assessed
regularly. The supplemental goal list provides Stormwater & GIS Services a reminder of alternative goals that
may be fulfilled with short-term adaptations of the assessment and monitoring plan.
Each of the assessments of goals is described generally below. Depending upon the goal and resources
available, the level of detail may be reduced in order to accommodate some assessment rather than omit
the assessment altogether. If and when resources are restored, efforts may be made to retroactively fill in
assessments. However, if monitoring data were not collected, retroactive assessments may not be possible.
Descriptions of the assessment are contained within SOPs, including those for outfall screening
investigations, and inspections.
Each of the program goals is listed with narrative descriptions of the types of assessments that may be
performed to meet the goal. The types of assessments may be modified to be more or less complex
depending upon many factors, including resources available for the assessment, software availability, and
monitoring data. Core goals are listed first, followed by supplemental goals.
Goal: To identify illicit discharges to area streams
Type(s) of Assessment: Assessments performed to identify potential illicit discharges are typically performed
in-situ immediately following the collection of some measurement. The measurements are compared
against a benchmark that may trigger environmental forensics and illicit discharge investigations. If the
benchmark is not exceeded, an investigation is not initiated. These assessments may be performed on any
flowing water in the collection system during dry weather. These assessments may also be performed during
other types of outdoor work activities when the technician has reason to suspect an illicit discharge.

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Goal: To identify pollution problem areas within the City of Durham
Type(s) of Assessment: Two different types of assessments may be performed to identify problem areas
within the City, by geographically analyzing the locations of IDDE investigations and by geographically
analyzing in-stream water quality monitoring data. Each method can be used to highlight areas with
problems, although the types of problems identified are slightly different. Assessing problem areas by
analyzing the locations of investigations highlights areas where pollution prevention activities may be
targeted. Assessing problem areas by analyzing in-stream water quality monitoring data highlights areas
when pollution is reaching the stream, or where hydrology has altered the stream. In these cases, an
investigation may be needed to identify the source of the pollution problem, or further scientific study may
be needed to diagnose hydrologic or structural problems.
Goal: To assess compliance with state water quality programs, including TMDLs and nutrient management
strategies
Type(s) of Assessment: All assessments associated with this goal involve comparing conditions monitored in
Durham to state and federal water quality program targets. In most cases, these assessments involve a
direct comparison of water quality monitoring data to a state water quality standard for a specific parameter
(e.g., dissolved oxygen). In some cases, where the state water quality standard is less informative, the
comparison may be performed against federal ambient water quality criteria. This is the case with several
metals. Lastly, goals for TMDLs and nutrient management strategies are often expressed in terms of mass
per time. In these cases, additional calculations are needed before the comparisons can be performed.
Goal: To evaluate the performance of SCMs
Type(s) of Assessment: Performance assessments of SCMs may include determining pollutant removal
efficiencies or evaluating changes to discharge hydrographs, depending upon the goal of the specific study
or site. SCM performance may be evaluated at industrial, commercial, or residential locations. The
parameters evaluated will vary based on the land use draining to the SCM, although most will include
nutrients because of the nutrient management strategies. These types of assessments are typically
performed using monitoring data over multiple seasons.
Goal: To determine pollution removal credits
Type(s) of Assessment: Determining pollution removal credits is a relatively new goal initiated shortly after
the adoption of the Falls Lake rules. However, this goal can apply to any area with a TMDL. These types of
assessments all intend to quantify the amount of pollution that is removed from surface water. All programs
in Stormwater & GIS Services may be evaluated to determine pollution removal credits, including Illicit
discharge elimination and low impact development retrofits.
Goal: To identify overall water quality trends
Type(s) of Assessment: Accountability is central to this goal, which includes a desire that water quality
improve over time. Assessments of overall water quality trends may be as simple as graphical
representations and professional judgments to determine if water quality is getting better, worse, or staying
about the same. Assessments may also be more complicated, using statistical methods that attach a level of
confidence with statements about trends. These assessments may be performed on individual monitored
parameters, or on a composite parameter such as the Durham Water Quality Index.

Goal: To evaluate the water quality impacts of urban stormwater on area streams
Type(s) of Assessment: All of the previous assessments contribute to this goal. The way the assessment is
analyzed is slightly different when considering widespread impacts of urban Stormwater. For example,
quantifying the pollutants discharged during specific types of activities, such as concentrated washing of
vehicles or maintenance of AC units, characterize what may be washed into the stormwater collection
system and ultimately area creeks when these activities do not comply with local ordinances.

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7.9.3 Monitoring Programs
The City of Durham has four overlapping monitoring programs. Each program generates monitoring data for
different assessment purposes. The ambient monitoring program generates monitoring data that describe
the condition of streams and rivers in the City of Durham. This program generates data that can be used to
assess changes over time as well as to identify specific changes in a watershed. Effluent monitoring from a
stormwater perspective, versus a wastewater perspective, is associated with any discharge to the municipal
separate storm sewer system (MS4) of a substance that is not water. Effluent monitoring conducted by
Stormwater & GIS Services is usually in response to a suspected or confirmed discharge of a substance that
is not water. Stormwater control measures (SCMs) or best management practices (BMPs) are structural or
non-structural practices that are put into the landscape with the intent of controlling non-point source
pollution in runoff. Although many of these practices have estimates of how well they perform in the
landscape, the variation in construction techniques or implementation methods may result in higher or lower
removal of pollution. Stormwater & GIS Services has completed studies of structural SCMs to determine
their effectiveness in the City of Durham landscape. Other monitoring studies are designed and executed as
needed based on City priorities. These other studies are typically short-term and focus on a specific
outcome.
Table 7-14 City of Durham Monitoring Goals and Programs

Goals Ambient In-Situ or Screening-Level SCM Special studies Core Identify illicit discharges  
Identify problem areas  
Assess compliance with state WQ programs   Supplemental Overall trends   
Evaluate performance of SCMs  
Determine pollution removal credits    
Assess overall quality of City’s streams 
Evaluate effects of urban SW on City’s streams    

Quality assurance is a high priority of the City of Durham. Water quality monitoring data has many uses,
including the development of regulations, assessment of conditions, and for enforcement purposes.
Enforcement may be performed by the City, or on the City. A serious commitment to quality is, therefore,
necessary to ensure that monitoring data is of the highest quality and comparable to data collected by state
and federal entities. The Stormwater Service’s quality assurance program requires a Quality Assurance
Project Plan (QAPP) that meets EPA requirements (EPA 1996) be developed for each program or project. A
QAPP describes a project’s data quality objectives and how the study design will ensure that those data
quality objectives are met through activities related to project management, data generation and acquisition,
project oversight and assessment, and data validation and verification. Other QA efforts include regular split
sampling with contract laboratories and the state water quality laboratory.
Stormwater & GIS Services utilizes an internal planning and assessment process when considering changes
to existing or establishment of different monitoring programs and projects for the coming two-three years.
This allows Stormwater & GIS Services to respond to emerging concerns and issues within the City’s
watersheds.

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7.9.3.1 Ambient Stream Monitoring
The Ambient Stream Monitoring program supports the following assessment goals:
• To identify pollution problem areas within the City
• To assess compliance with State water quality programs, including TMDLs, water quality standards, and nutrient
management strategies
• To determine pollution removal credits
• To identify overall trends to water quality
• To evaluate the water quality impacts of urban stormwater on area streams
The City’s Ambient Stream Monitoring program is comprised of three major components: water chemistry, aquatic
biological communities (benthic macroinvertebrates), and hydrology. These three different types of monitoring allow the
City of Durham not only the opportunity to evaluate streams independently of the State, but also to verify results
obtained by the State.
Similar to the NC Division of Water Resources (DWR) Ambient Monitoring System, Durham’s Stormwater &
GIS Services uses a rotating watershed approach, with comprehensive chemical and biological monitoring in
each basin occurring every two years (Table 7-15). The rotating watershed approach was implemented in
calendar year 2011 and allows a wider geographic coverage of monitoring of the City’s streams than would
otherwise be possible with current resources. However, a subset of sites are monitored every year for water
chemistry and hydrology due to their use in calculating loading for certain parameters of concern.

Table 7-15. Rotating Monitoring Schedule
Neuse River Basin
Watersheds
Cape Fear River Basin
Watersheds
Odd Years Ellerbe Creek
Panther Creek
Stirrup Iron Creek
Crooked Creek
Little Creek
New Hope Creek
Even Years Eno River
Lick Creek
Little Lick Creek
Little River
Northeast Creek
Third Fork Creek

One full monitoring cycle includes the planning, monitoring, summarizing and reporting of monitoring data.
This is generally accomplished in 18 months. Stormwater & GIS Services re-evaluates the monitoring
program near the end of each calendar year. Existing monitoring sites are reviewed to determine if any
should be added or removed, or if anything unusual has occurred at a particular station. New potential
stations may be proposed to evaluate emerging concerns or issues. When all results have been received
from the analytical laboratory, annual summaries for each watershed are generated for each monitoring
program and reported on the Stormwater & GIS Services website. All staff of the Water Quality Unit of
Stormwater & GIS Services work to ensure that scheduled monitoring and reporting is completed.

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Water Chemistry
The ambient chemistry portion of the monitoring program focuses on surface water. Through field or
laboratory analysis of selected parameters, the ambient chemistry program provides brief looks, or
“snapshots,” of water quality. These snapshots can be used to identify short and long-term trends and
sources of pollution. Additional information is available in the Ambient Water Chemistry Monitoring Program
Quality Assurance Project Plan (Durham 2014a).
Ambient water chemistry monitoring consists of monthly grab samples for laboratory analysis and collection
of field parameters (e.g., temperature, dissolved oxygen, pH, specific conductance, and turbidity), using
multi-parameter field meters. In general, all sites have identical parametric coverage, though additional
parameters may be collected due to site-specific concerns. Monthly sampling dates for all sites are
scheduled during the planning phase, so a wide variety of site conditions (particularly hydrology) are
generally represented each year. All sites within a single watershed are sampled on the same day whenever
possible.
Benthic Macroinvertebrate Community Assessments
The City of Durham uses benthic macroinvertebrate monitoring as a way of assessing the ability of the City’s
streams to support aquatic life. Benthic macroinvertebrates are found in almost all aquatic environments,
are less mobile than many other groups of organisms (e.g., fish), and are of a size that makes them easily
collectible. Benthic macroinvertebrates show responses to a wide variety of potential pollutants, including
those with synergistic or antagonistic effects, as well to physical conditions, including quality and availability
of instream habitat. The City of Durham program is modeled after the DWQ benthic macroinvertebrate
program.
A majority of the benthic macroinvertebrate sites are co-located with ambient chemistry monitoring stations.
In general, Stormwater & GIS Services strives to include at least one benthic macroinvertebrate site in each
watershed monitored that year. Results are generally used to track changes over time, so sites generally
have a robust history of results. Samples are collected once during the year, as described in the City of
Durham’s Standard Operating Procedures for Benthic Macroinvertebrates (Durham 2014b), with small
streams sampled in the spring (March – May) and larger streams and rivers sampled in summer (June –
September). Data collections are overseen by an experienced benthic biologist, who is also responsible for
sample identifications, data analysis, calculation of bioclassifications, and data interpretation. Field
parameters such as pH, specific conductance, turbidity, dissolved oxygen and temperature are collected
during each sampling event. A qualitative instream habitat assessment is also completed.
Hydrologic Monitoring
The hydrology of City streams is critical to understanding the types of pollutants entering a stream and their
impacts, though modifications to the hydrologic cycle can also directly impact stream morphology, sediment
transport, and the quality of instream habitat
Water enters streams through rainfall, runoff, groundwater discharge, and direct discharges. It is not
economically or technically feasible to monitor each of these routes of water entry for all City streams,

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therefore hydrologic monitoring currently targets stream discharge and stage, and rainfall. A brief
description of each type of monitoring is provided below:
• Rainfall: At least hourly measurements of rainfall are needed to understand the short-term impacts of rainfall on
stormwater runoff and creek discharge. Stormwater & GIS Services obtains this type of information through a
variety of means, including partnerships with the NC Climate Center and the US Geological Survey.
• Stream Discharge: All of the continuous discharge monitoring that occurs within the City of Durham is
accomplished in partnership with the US Geological Survey, which measures discharge every 15 minutes. The
USGS is the recognized national technical leader in stream discharge measurements. The stream discharge
measurements in the City of Durham are co-funded by Stormwater & GIS Services, the Army Corps of Engineers,
the Triangle Area Water Supply Monitoring Project, and the City of Raleigh.
• Stream Stage. A reasonable surrogate to stream discharge, which is time consuming and expensive to measure, is
stream stage. Stream stage also provides a measure of peak flow and is useful in areas when flooding is a
concern. Stream stage measurements in the City of Durham are accomplished by Stormwater & GIS Services and
in partnership with the US Geological Survey.
7.9.3.2 In-Situ or Screening-Level Monitoring
This effort supports the following assessment goals:
• To identify illicit discharges to area streams
• To determine pollution removal credits
• To identify overall trends to water quality
• To evaluate the water quality impacts of urban stormwater on area streams
In-situ or field screening level monitoring programs include the illicit discharge detection program, the outfall
screening program, stream forensics studies, and response to sewer spills. Each of these programs requires
rapid analysis of surface water to determine if indicators of common types of illicit discharges are present
and to what extent. The methods used for monitoring are similar. Small samples of water are collected and
analyzed in the field to determine water quality conditions.
The Stormwater & GIS Services staff uses portable colorometric field chemistry kits to provide support for
real-time pollution tracking. The use of the field screening methods is described in the Stormwater & GIS
Services Investigations QAPP (Durham 2013?) and the Outfall Screening QAPP (Durham 2013).
On a case-by-case basis, there may be a need for detailed or precise measurements such as those provided
by an analytical chemistry laboratory. When these cases arise, grab samples may be collected per the QAPP
and delivered to a state-certified analytical laboratory.
Field screening methods are performed on an as-needed basis and thus frequency and site location cannot
be specified in advance. Frequency may consist of before and after monitoring to characterize the problem
and resolution. More frequent analysis may be needed if an ongoing problem has been identified. Similarly,
monitoring locations may vary. Monitoring locations may include outfalls or other discharge pipes, ditches,
storm sewers and surface waters. In the case of outfall screening or illicit discharge detection,
documentation of frequency and locations will be provided in the Stormwater & GIS Services water quality
investigations database.
7.9.3.3 Stormwater Control Measures (SCM) Monitoring
Monitoring of SCMs supports the following assessment goals:
• To evaluate the performance of SCMs
• To determine pollution removal credits
• To evaluate the water quality impacts of urban stormwater on area streams

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SCM monitoring may occur for a variety of reasons, on a variety of types of SCMs. SCM monitoring is typically
performed during storm events, since SCMs are designed to capture and treat stormwater runoff. Due to the
unpredictability of storm events, technicians will usually set up automated sampling equipment to begin
collecting samples in response to hydrologic changes during a storm event, such as a rise in stage. Wet
weather monitoring of SCMs is complicated and time-consuming. In many cases, Stormwater & GIS Services
will partner with local universities to accomplish wet weather monitoring on specific structural SCMs or SCM
enhancements.
The City of Durham has a wide variety of SCMs installed in the landscape, including dry ponds, extended dry
ponds, wet ponds, bioretention areas, and constructed wetlands. The City has also installed low impact
development retrofits, some of which are also monitored. Each of these SCMs functions in a different way
and may require different deployment for monitoring. Since SCM monitoring is typically performed as part of
a special study (Section 4.4), a site-specific monitoring plan is written prior to collecting samples. These site-
specific monitoring plans, usually in the form of a QAPP, describe the monitoring goals, locations, equipment
deployment, parameters, and quality assurance.
7.9.3.4 Special Studies
Special studies may be initiated to support any of the assessment and monitoring program goals. These
studies are typically short-term, occurring over 12 to 24 months. Special studies may include water
chemistry, biological monitoring, hydrologic monitoring, or any other type of monitoring. In the past, these
studies have included activities such as habitat assessments, sediment quality monitoring, high flow
sampling, manual measurements of stream discharge, and surveys of aquatic weeds in addition to more
traditional water quality assessments.
Special studies may be generated from concerns or initiatives throughout Public Works. These studies are
vetted within the Water Quality Unit and if they are selected, a QAPP is written for the study, as required by
the Water Quality Unit’s quality assurance program. QAPPs for special studies follow EPA guidance (EPA
1996.
Special studies may include contractors as well as technical staff from within Stormwater & GIS Services. In
many cases, contract laboratory support is used for these studies because of a varied parameter list or
alternate media (e.g., soil, algae). Special studies may also involve other agencies.
When data collection is not involved in a special study, a study plan will be developed instead of a QAPP. This
type of study is an alternate assessment of data already collected by the City of Durham and any partnering
agency. Both QAPPs and study plans are retained by the City of Durham electronically for an indefinite time
period, but no less than 10 years.

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7.9.4 Reporting
Stormwater & GIS Services generates a large amount of
monitoring data within any 12-month period. Program
assessments are also performed on a regular basis and are
reported to the state permitting agency through annual reports,
the largest of which is the NPDES annual report. To
communicate with the residents of Durham, watershed
summaries are prepared annually and provided on the City’s
website. These summaries describe results from the core
assessments in a less technical manner. One of the features of
this report is the Water Quality Index, an index developed for
Durham streams. This index has been adopted by City leaders
as a benchmark for the City Strategic Plan.

Durham Water Quality Index
Stormwater & GIS Services created a water
quality index (WQI) to relay surface water
chemistry information to the citizens of
Durham in an easily understood format. The
water quality index is unique to Durham and
accounts for the following chemical and
physical parameters: dissolved oxygen,
turbidity, fecal coliform, total nitrogen, total
phosphorus, 5-day biochemical oxygen
demand, dissolved copper and dissolved
zinc. The annual average water quality index
is provided annually in online summaries and
in the City’s Sustainability and Strategic
Plans.

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7.10 Total Maximum Daily Loads (TMDLs)
This TMDL section of the permit is designed to ensure that MS4s address waste load allocations provided in
EPA approved TMDLs. The permit provides two objectives for the TMDL section, as follows:
• Determine whether the MS4 discharges to receiving waters located within a TMDL watershed and identify the
pollutant(s) of concern (POC). For all TMDLs with a NPDES MS4 regulated stormwater waste load allocation
(WLA) assigned to the permittee, the permittee shall determine whether the POC have potential to occur in
MS4 stormwater discharges.
• Utilize BMPs within the six minimum measures and the permittee’s TMDL Plan(s) to meet the permittee’s
assigned NPDES MS4 regulated stormwater WLA identified in the approved TMDL to the maximum extent
practicable and to the extent allowable by law.
• The permit considers the municipal MS4 to be in compliance with the TMDL if conditions of the permit
are met, including developing and implementing appropriate BMPs within the six minimum measures to
address the permittee’s MS4 wasteload allocation. The permit recognizes that improved water quality is
the expected outcome of BMPs included in this section.

Table 7-16: BMP Summary Table for EPA Approved TMDL Wasteload Allocations
BMP Measurable Goals Frequency Responsible
Position
(a) Identify.
Describe and
map watershed,
outfalls, and
streams
Within 12 months of an EPA approved TMDL with
a permittee wasteload allocation the permittee
shall prepare a plan that:
• Identifies the watershed(s) subject to an
approved TMDL with an approved wasteload
allocation assigned to the permittee,
• Includes a description of the watershed(s)
and
• Includes a map of the watershed showing
streams and outfalls.
• Identifies the locations of currently known
major outfalls within its corporate limits with
the potential of contributing to the cause(s)
of the impairment to the impaired segments,
to their tributaries, and to segments and
tributaries within the watershed contributing
to the impaired segments; and
• Includes a schedule (not to exceed 6
months) to discover and locate other
unknown major outfalls within its corporate
limits that may be contributing to the cause
of the impairment to the impaired stream
segments, to their tributaries, and to
segments and tributaries within the
watershed contributing to the impaired
segments.
Within 12
months of an
EPA approved
TMDL
Water Quality
Analyst, Asst.
Water Quality
Manager

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Table 7-16: BMP Summary Table for EPA Approved TMDL Wasteload Allocations
BMP Measurable Goals Frequency Responsible
Position
(b) Evaluate
existing
measures
Within 12 months of an EPA approved TMDL with
a permittee wasteload allocation the permittee’s
plan shall:
• Describe existing measures currently being
implemented by the permittee designed to
achieve the MS4’s NPDES wasteload
allocation and to reduce the TMDL pollutant
of concern to the maximum extent
practicable within the watershed to which the
TMDL applies
• Provide an explanation as to how those
measures are designed to reduce the TMDL
pollutant of concern
• Continue to implement the existing measures
until notified by the Division
Within 12
months of an
EPA approved
TMDL, and
reviewed as
needed or
with each
permit cycle
Water Quality
Analyst, Asst
Water Quality
Manager
(c) Assessment of
available
monitoring data
Within 24 months of an EPA approved TMDL with
a permittee wasteload allocation the permittee’s
plan shall include an assessment of the available
monitoring data. Where long-term data is
available, this assessment should include an
analysis of the data to show trends.
Within 24
months of an
EPA approved
TMDL, and
reviewed with
each permit
cycle
Water Quality
Analyst
(d) Monitoring
Plan
Within 24 months of an EPA approved TMDL with
a permittee wasteload allocation the permittee’s
shall develop a monitoring plan for the
permittee’s assigned NPDES regulated wasteload
allocation as specified in the TMDL. The
permittee shall maintain and implement the
monitoring plan as additional outfalls are
identified and as accumulated data may suggest.
Following any review and comment by the
Division the permittee shall incorporate any
necessary changes to the monitoring plan and
initiate the plan within 6 months. Modifications
to the monitoring plan shall be approved by the
Division.
Within 24
months of an
EPA approved
TMDL, and
reviewed with
each permit
cycle
Water Quality
Analyst, Water
Quality
Specialists

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Table 7-16: BMP Summary Table for EPA Approved TMDL Wasteload Allocations
BMP Measurable Goals Frequency Responsible
Position
(e) Additional
measures
Within 24 months of an EPA approved TMDL with
a permittee wasteload allocation, the permittee
shall:
• Describe additional measures to be
implemented by the permittee designed to
achieve the MS4’s NPDES wasteload
allocation and to reduce the TMDL pollutant
of concern to the maximum extent
practicable within the watershed to which the
TMDL applies; and
• Provide an explanation as to how those
measures are designed to achieve the MS4’s
NPDES regulated wasteload to the maximum
extent practicable within the watershed to
which the TMDL applies.
Within 24
months of an
EPA approved
TMDL, and
reviewed with
each permit
cycle
Water Quality
Analyst, Water
Quality Specialist
(Investigations
and Inspections)
(f)
Implementation
plan
Within 48 months of an EPA approved TMDL with
a permittee wasteload allocation, the permittee
shall:
• Describe the measures to be implemented
within the remainder of the permit term
designed to achieve the MS4’s NPDES
wasteload allocation and to reduce the TMDL
pollutant of concern to the maximum extent
practicable;
• Identify a schedule, subject to Division
approval, for completing the activities
• Implement the permittee’s TMDL plan
Within 48
months of an
EPA approved
TMDL, and
reviewed with
each permit
cycle
Water Quality
Analyst, Water
Quality Specialist
(Investigations
and Inspections)
(g) Incremental
success
The permittee’s plan must outline ways to track
progress and report successes designed to
achieve the MS4’s NPDES regulated wasteload
allocation and to reduce the TMDL pollutant of
concern to the maximum extent practicable
within the watershed to which the TMDL applies
Each permit
cycle
Water Quality
Analyst
Reporting
The permittee shall conduct and submit to the
Division an annual assessment of the program
designed to achieve the MS4’s NPDES wasteload
allocation and to reduce the TMDL pollutant of
concern to the maximum extent practicable
within the watershed to which the TMDL applies.
Any monitoring data and information generated
from the previous year are to be submitted with
each annual report.
Annually
Water Quality
Analyst, Asst.
Water Quality
Manager

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• The permit also states that existing TMDL or Water Quality Recovery plans that address the pollutant of
concern through the six minimum control measures satisfy the objectives of this section of the permit.

7.10.1 Existing Programs for Northeast and Third Fork Creeks
The 2007 NPDES Stormwater permit required the City of Durham to develop Water Quality Recovery
Programs (WQRPs) for waters with assigned MS4 wasteload allocations in approved TMDLs. These WQRPs
included requirements such as identifying locations of MS4 outfalls within the impaired watershed,
developing a monitoring plan for each pollutant of concern, a schedule for discovering and locating unknown
MS4 outfalls, a regular assessment of available data, and implementation of BMPs. As described in Section
2.4, EPA approved TMDLs exist for Northeast and Third Fork creeks, for fecal coliform bacteria and
turbidity/TSS, respectively. The six minimum measures were enhanced with a goal of reducing levels of
pollutants of concern in MS4 discharges to Northeast and Third Fork Creeks. The WQRP components were
updated in each NPDES Annual Report.
Table 7-17. Water Quality Recovery Program Requirements (NCDENR 2007)
Required BMP
A Within 24 months of the effective date of this permit or of becoming subject to an approved TMDL, the
permittee shall
establish a Water Quality Recovery Program,
identify the locations of currently known MS4 outfalls within its jurisdictional area with the potential of
discharging the pollutant(s) of concern: to the impaired segments, to their tributaries, and to segments
and tributaries within the watershed contributing to the impaired segments, and
develop a schedule to discover and locate other MS4 outfalls within its jurisdictional area that may be
discharging the pollutant(s) of concern: to the impaired stream segments, to their tributaries, and to
segments and tributaries within the watershed contributing to the impaired segments.
B Within 36 months of the effective date of this permit or of becoming subject to an approved TMDL, the
permittee shall develop a monitoring plan for each pollutant of concern.
The monitoring plan shall include the sample location by verbal description and latitude and longitude
coordinates, sample type, frequency, any seasonal consideration, and a monitoring implementation
schedule for each pollutant of concern.
Where appropriate, the permittee may reduce the monitoring burden by proposing to monitor outfalls
that the Division would consider substantially similar to other outfalls.
The permittee may also propose in-stream monitoring where it would complement the overall monitoring
plan.
The monitoring plan shall be adjusted as additional outfalls are identified in accordance with the
schedule required in (a) above and as accumulating data may suggest.
C The permittee shall include the location of currently known MS4 outfalls with the potential of discharging
the pollutant(s) of concern, the schedule for discovering and locating currently unknown MS4 outfalls with
the potential of discharging the pollutant(s) of concern, and the monitoring, in the first annual report due
no earlier than 12 months after the applicability of a TMDL.
D The next and each subsequent annual report shall include an assessment of the available data for each
pollutant of concern, and an assessment of the effectiveness of the BMPs employed, to determine what, if
any, additional BMP measures may be necessary to address the MS4 NPDES regulated Wasteload
Allocation identified in the TMDL.
The permittee shall implement appropriate BMPs to control the MS4 NPDES Waste Load Allocation
portion of the pollutant load for the pollutant(s) of concern to the maximum extent practicable.

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Table 7-17. Water Quality Recovery Program Requirements (NCDENR 2007)
Required BMP
Implementation of the appropriate best management practices constitutes compliance with the standard
of reducing pollutants to the maximum extent practicable.
E Following any review and comment by the Division on the TMDL Water Quality Recovery Program and
monitoring plan, the permittee shall incorporate any necessary changes into the program and/or
monitoring plan. The permittee shall incorporate the approved TMDL Water Quality Recovery Program into
the Stormwater Plan.

A 2017 review of monitoring data in Northeast Creek showed levels of fecal coliform bacteria increased
significantly at two different city monitoring locations. A standard update was provided in the 2017-2018
annual report, and an effort began in early 2018 to develop new pollution control plans for Northeast and
Third Fork Creeks to address the degrading water quality. The updated plans, referred to as TMDL Response
Plans, include additional enhancements to the six minimum control measures. The enhancements also
include measures to identify sources not previously discovered, plans for agencies that have complementary
authority for sources of pollution, and program modifications and additions to address other sources. TMDL
Response Plan development was expanded to include other city and county departments that have authority
to address the discharge of the pollutants of concern. After collectively identifying actions that could address
the pollutants of concern, these actions were ranked and order-of-magnitude cost estimates were
developed. The ranks were based on best professional judgement regarding the potential impact of the
action and whether the action would prevent a discharge to the aquatic environment. Additional actions
include modifications to the minimum control measures described in the NPDES permit, other structural
control measures that could be implemented by the stormwater program, and measures clearly outside of
stormwater program authority. Additional funding was not identified in the plans. Future implementation is
dependent upon funding and resources. TMDL Response Plans for Northeast and Third Fork Creeks are
provided in Appendix I.
Concurrent with the development of the TMDL Response Plans, the 2018 NPDES permit was issued. The
2018 permit includes many of the same elements as the WQRPs. Those items that were completed in the
WQRPs and continue to be required in the 2018 permit will continue to be reported or updated in the annual
reports.
Funding. Funding for the TMDL Response Plans will include funds garnered from the stormwater
operating budget as well as capital improvement projects. The current plans do not include project budgets.
Funding requests less than $50,000 must be approved by the City Manager. Requests for greater than
$50,000 must be approved by the City Council. For projects to be undertaken by County agencies, requests
for funding must be approved by the County Commissioners. As implementation actions begin, cost
estimates will be prepared for each action that moves forward, including those that are completed using
existing resources.
7.10.2 Future TMDL Response Plans
For EPA approved TMDLs after 2018, the City will complete all required BMPS in Table 7-16 on the time
schedule provided. As specified, planning-related BMPs occur during the first 24 months (two years),
including mapping streams, locating outfalls, evaluating existing measures, assessing monitoring data,
developing a monitoring plan, and describing additional measures to be implemented. Implementation is
scheduled to begin within 48 months of EPA approval.
The planning aspects of TMDL Response Plans are less time consuming because most of the data already
exists, albeit in separate locations. Extensive GIS analysis has already identified outfalls throughout the City.
The current GIS layers include most of the stormwater and wastewater infrastructure in the City. This
includes major and minor outfalls, inlets, catch basins, etc. These GIS layers are used during dry weather

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outfall screening. New, previously unknown, pipes identified while in the field are georeferenced and
brought to the attention of the GIS group for inclusion in the stormwater infrastructure inventory.
Stormwater staff conducts stream walks as part of watershed planning activities. Unmapped infrastructure
is noted during these stream walks and is brought to the attention of those that maintain the infrastructure
maps. Watershed plans including stream walks have been conducted for the Ellerbe, Third Fork, Northeast,
Crooked (Southwest), and Little Lick Creeks, and the Eno River. The New Hope Creek watershed plan,
including stream walks, will begin in calendar year 2019. The remaining watersheds without watershed
plans are Lick and Stirrup Iron Creeks.
The City has an existing database of constructed SCMs, including those constructed with new development
and retrofit projects in the existing landscape. The City also has an ambient stream monitoring program that
includes water chemistry collection in most watersheds of the City. Ambient monitoring data is
supplemented with special studies as needed, and a special study may be needed to evaluate some aspect
of a TMDL. As mentioned in Section 7.9, special studies are planned at least triennially (every three years).
Identifying implementation measures, particularly within the minimum control measures, will depend on the
pollutant of concern and knowledge of the drainage area to the impaired segment. When sources of the
pollutant of concern are apparent early in the planning process, the minimum control measures can be used
to reach residents and businesses in the target area. The IDDE and Inspections programs can be used to
bring discharges into compliance. When the potential sources are diffuse or difficult to identify, a different
approach will be needed. Additional measures may focus on identifying the sources and pattern of discharge
and the geographic location.

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7.11 References
City of Durham (Durham). 2013a. Outfall Screening and Monitoring Standard Operating Procedures.
Stormwater & GIS Services, Water Quality Unit.
Ibid. 2013c. Illicit Discharge Detection and Elimination (IDDE) Investigations, Standard Operating
Procedures. DRAFT–In Revision. Stormwater & GIS Services, Water Quality Unit.
Ibid. 2013d. Industrial Stormwater Inspections Program Manual. DRAFT–In Revision. Stormwater & GIS
Services, Water Quality Unit.
Ibid. 2014a. Ambient Water Chemistry Monitoring Program Quality Assurance Project Plan. Stormwater &
GIS Services, Water Quality Unit. October
Ibid. 2014b. Standard Operating Procedures for Benthic Macroinvertebrate Community Monitoring for
Determination of Bioclassifications (DRAFT). Stormwater & GIS Services. Water Quality Unit.
Griffith, G.E., Omernik, J.M., et al. 2002, Ecoregions of North Carolina and South Carolina, (color poster with
map, descriptive text, summary tables, and photographs). Reston, Virginia, U.S. Geological Survey (map
scale 1:1,500,000).
NC Department of Environmental Quality (NC DEQ). 2018. Permit No. NCS000249 to Discharge Stormwater
Under the National Pollutant Discharge Elimination System. Division of Energy, Mineral, and Land Resources
US Environmental Protection Agency (EPA). 1992. NPDES Storm Water Sampling Guidance Document. EPA
833-B-92-001. Office of Water.
US Environmental Protection Agency (EPA). 1996. The Volunteer Monitor’s Guide to Quality Assurance
Project Plans. EPA 841-B-96-003. Office of Wetlands, Oceans and Watersheds 4503F.
US Environmental Protection Agency (EPA). 2002. Guidance on Choosing a Sampling Design for
Environmental Data Collection. EPA QA/G-5S. Office of Environmental Information. Washington, DC