NCS000249_OTHER_20110805

STORMWATER DIVISION CODING SHEET
MS4 PERMITS
PERMIT NO.
L �
DOC TYPE
❑FINAL PERMIT
❑ ANNUAL REPORT
0 APPLICATION
❑ C�PLIANCE
N�OTHER
DOC DATE
❑ `� D � �/
YYYYMMDD

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA,•GEORGIA 30303-8960
AUG 5 2011
CERTIFIED MAIL 7005 2570 0001 4886 8137
RETURN RECEIPT REQUESTED
Mr. Keith Huff
Director, Stormwater Division
City of Winston-Salem
Suite 53, City Hall
101 North Main Street
Winston-Salem, North Carolina 27101
RECEIVED
N.C. DeDu of ENR
AUG 18 2011
Winston Salem
Regional Office
AUG - 8 411
UENft - WATER OUAIIn
56aFAGE W4TER PROTEL,TION c
Rc: National Pollutant Discharge Elimination System Permit No. NCS000249
City of Winston-Salem Municipal Separate Stormwater Sewer System
Dear Mr. Huff
As discussed with you via telephone on July 12, 2011, the U.S. Environmental Protection Agency plans to
conduct a Compliance Stormwater Municipal Separate Storm. Sewer System (MS4) Inspection (Inspection)
of the City's MS4 during the week of August 1, 2011. The EPA Inspection Team will consist of the EPA's
contractor, Science Applications and International Corporation's (SAIC) representative Mr. Jerry Whitham
and Mr. Mike Randall of the North Carolina Department of En%ironment and Natural Resources (NV`CDENI R).
Inspectors from the NCDENR Field Office may also be in attendance.
The Inspection Team will be conducting in-depth inspections of the Industrial and High Risk Runoff,
Construction Site Runoff and Illicit Discharges and Improper Disposal Programs. In addition to discussing..
these Programs with you and your staff, the Inspection Team would like to review several construction site (plan
review, inspection, and enforcement), industrial site (inspection and enforcement), and IDID (inspection and
enforcement) files. During the inspection, the Mr. Whitham will also perform an overview of field activities for
these Programs. The overview inspections should include at least one large, one small, and one municipally -
operated industrial/high risk site and at least one commercial and one residential construction site in the schedule.
As discussed during our conference call on July 18, 2011, Mr. Whitham will contact you to set the schedule for
the Inspection.
As an addendum and pursuant to Section 308 of the Clean Water Act (CWA), 33 U.S.C. § 1318, the EPA hereby
requests that the City provide the information set forth in Enclosure A regarding the City's MS4. The City is
required to provide this information within thirty (30) days of receipt of this letter. The response should be
directed to:
U.S. Environmental Protection Agency, Region 4
Clean Water Enforcement Branch
Water Protection Division
Ms, Susan Pope
61 Forsyth Street, SW
Atlanta, Georgia 30303-8960
Phone: [phone]
Email: [e-mail]
Internet Address (URL) • httpjlwww.opa.gov
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The City's response to this information request should specifically reference the particular section and item
number of the request and should be organized for the purpose of clarity. In the case where a program is being
implemented by another entity, please state the name of the entity implementing the program and provide
documentation, such as in a Memorandum of Agreement, authorizing such implementation, information may
be provided pia disc rather than paper copy in most cases. In addition, all information submitted must be
accompanied by the following certification signed by a responsible City official in accordance with 40 C.F.R. §
122.22:
!"certify under, penalty. of law that this document and all attachments were prepared under my direction
.gLc►jpe , Mon in accordaride with a system designed to assure that qualified personnel properly gather
and evaluate the'inforniation 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 thc'btst afiny owledge ind belief, true, accurate, and complete. I am aware that there are significant
;penalties for submitting false, information, including the possibility of fine and imprisonment for knowing
violation's".'
Failure to comply witli'fliis inforiaton request may result in enforcement proceedings under Section 309 of
the CWA, 33 U.S.C. § 1319, which could result in the judicial imposition of civil or criminal penalties or the
administrative imposition of civil penalties. In addition, there is potential criminal liability for the falsification of
any response to the requested information.
The City shall preserve until further notice all records (either written or electronic) which exist at the time of
receipt of this letter that relate to any of the matters set forth in this letter. The term "records" shall be interpreted
in the broadest sense to include information of every sort. The response to this information request shall include
assurance that these record protection provisions were put in place, as required. No such records shall be disposed
of until written authorization is received from the EPA., Region 4.
If you believe that any of the requested information constitutes confidential business information, you may assert
a confidentiality claim with respect to such information except for effluent data. Further details, including how to
make a business confidentiality claim, are found in Enclosure B.
Please contact Ms. Pope should you have questions and to further discuss details of the Inspection.
Sincerely,
enisse D. Diaz, Chief
Clean Water Enforcement Branch
Water Protection Division
Enclosures (2)
cc: NCDENR

INFORMA IO REQUEST
WINSTON-SALEM, H CAROLINA (the City)
Municipal Separate Storm Sewer System (MS4) Program — Phase I
ENCLOSURE A
Provide a copy of the current MS4 operating permit.
2. Provide a copy of the MS4's Stormwater Management Plan, including any inter- or intra-
agency agreements.
3. Provide a copy of the MS4's Annual Report and any related correspondence for the past
two years.
4. ' , Provide a copy of the City's organizational chart.
5. Provide copies of all legal ordinances which govern the MS4.
fi. For structural controls and MS4 collection system, provide the following:
a. Provide copies of inspection and maintenance program logs and activities for the
past year, including any maps of outfalls.
b. Provide copies of Standard Operating Procedures (SOPS), maintenance or
guidance manuals.
For areas of new development'and significant redevelopment and construction site runoff
provide the following information:
a. Copies of the MS4's comprehensive master planning process, including
management objectives;
b. Inventory of future urban development, sensitive areas, and active areas of
development and redevelopment;
C. Post -construction stormwater management requirements, including any new or
proposed ordinances;
d. Standards and guidance for construction; design criteria and performance
standards for stormwater controls and best management practices (BMPs);
include SOPS and guidance manuals;
e. Site development review SOPs, including the Stormwater Pollution Prevention
Plan (SWPPP) review procedures;
f. SOPs for inspections, including setting inspection priorities, and enforcement;
g. Inspection records, checklists, and enforcement records for the previous two
years; and
h. Training records for construction inspectors for the previous year.
8. For -roadways, provide the following:

a. Provide copies of inspection reports, operation and maintenance records and
activities, including storm water conveyances, litter control and street sweeping
for the previous two years.
b. Provide any SOPS, maintenance or guidance manuals.
9. For flood control projects, provide the following information:
a. Inspection procedures;
b. Evaluations for any existing or new flood control projects over the previous two
years;
C. Copy of the hydrologic model for the City; and
d. Water quality impact assessments.
10. For pesticide, herbicide, and fertilizer applications, provide:
a. The types, amount, and storage locations for pesticides, herbicides and fertilizers,
b. Training, licenses and certification records for applicators;
C. Copies of public outreach and education materials; and
d. Copies of any SOPS, maintenance or guidance manuals.
i t . For spill prevention and response, provide the following:
a. Copies of any spill response logs or incident reports for the previous two years;
b. Copies of any SOPs to prevent, contain, and responds to spills, coordination
documents, maps,, etc. used for spill response;
C. Copies of any enforcement documents.
d. Staff training records for the previous two years.
12. For illicit discharges and improper disposal, provide the following information:
a. Procedures/SOPs to prevent,.detect and eliminate illicit discharges, cross-
connectiocis and improper disposal;
b. Identify non-stonn water discharges allowed to be discharged to the MS4;
C. Copies of inspection logs/reports and enforcement records for the previous two
years;
d. Dry .weather field screening methodology, prioritization and procedures for
identifying responsible parties;
e. Copies of citizen complaint records and MS4 response;
f. Information regarding septic system failures leaking into the MS4 for the previous
two years; and
g. Staff training records for the previous two years.
13. For industrial facilities, including, but not limited to, municipal landfills, hazardous waste
treatment sites, municipally -owned facilities, industrial and commercial sites, provide the
following information:
a. Inventory of industrial stormwater dischargers/discharges;
A-2

b. Inspection and enforcement records for the previous two years;
C. Examples of inspection checklists;
d. SOPs or guidance manuals for inspections and enforcement;
e. Procedures for prioritization of inspections and verifying SWPPPs;
f. Inspector training records for the previous two years;
g. List of municipal operations/contractor operations; and
h. Copies of Notices of Intent and SWPPPs for municipally -operated sites.
14. Provide information on public education and outreach programs regarding:
a. IIlicit discharges or improper disposal of materials into the MS4;
b.- Disposal of used oil, household hazard wastes, fertilizer, leaf and grass clippings,
animal wastes; and
C. Other education and/or outreach programs and materials.
15. For the MS4's monitoring program, provide the following information:
a. Methodology for calculating event mean concentration and seasonal pollutant
loading;
b. Copies of any SOPS or guidance manuals for monitoring procedures;
C. SOP for identifying and prioritizing problem areas and list of problem areas;
d. Status of monitoring program;
e. Method for compliance with Total Maximum Daily Load conditions.
16. Provide fiscal analysis for each major program element of your MS4 program for the
}previous two years and for the proposed year.
A-3

ENCLOSURE B
RIGHT TO ASSERT BUSINESS CONFIDENTIALITY CLAIMS
(40 C.F.R. Part 2)
Except for effluent data, you may, if you desire, assert a business confidentiality claim as to any
or all of the information that EPA is requesting from you. The EPA regulation relating to
business confidentiality claims are found at 40 Code of Federal Regulations (C.F.R.) Part 2.
If you assert such a claim for the requested information, the EPA will only disclose the
information to the extent and under the procedures set out in the cited regulations. If no business
confidentiality claim accompanies the information, the EPA may make the information available
to the public without any further notice to you.
40 C.F.R. §2.203(b). Method and time of asserting business confidentiality claim. A business
which is submitting inforrnation to the EPA may assert a business confidentiality claim covering
the information by placing on (ear attaching to) the information, at the time it is submitted to the
EPA, a cover sheet, stamped or typed legend, or other suitable form of notice employing
language such as "trade secret," "proprietary," or "company confidential." Allegedly confidential
portions of otherwise non -confidential documents should be clearly identified by the business,
and may be submitted separately to facilitate identification and handling by the EPA. If the
business desires confidential treatment only until a certain date or until the occurrence of a
certain event, the notice should so state.

r
,ZED Sr,,
t>A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
�� Yz REGION 4
i ��%% V ATLANTA FEDERAL CENTER
02 61 FORSYTH STREET
;�Hr'�< ATLANTA, GEORGIA 30303-8960
NOV z 1 2C06
CERTIFIED MAIL 7006 0810 0004 1129 0825
RETURN RECEIPT REQUESTED
Mr. Keith Huff
Stormwater Manager
Stormwater Department
City of Winston-Salem
P. O. Box 2511
Winston-Salem, NC 27102
SUBJ: NPDES PetTnit No. NCS000247
City of Winston-Salem Municipal Separate Storm Sewer System
Dcar Mr. Huff:
During the period covering June 27-29, 2006, the Environmental Protection Agency's
(EPA) contractor, Science Applications International Corporation (SAIL), in conjunction with
the North Carolina Department of Environment and Natural Resources (NCDENR) performed a
Municipal Separate Storm Sewer System (MS4) Audit of the City of Winston-Salem. The Audit
was conducted to evaluate the City's compliance with the requirements of Section 402(p) of the
Clean Water Act (CWA), 33 U.S.C. § 1342(p), the regulations promulgated thereunder at 40
Code of Federal Regulations Part 122.26, and the North Carolina National Pollutant Discharge
Elimination System (NPDES) Permit No. NICS000247 (the Permit), effective November 1, 2001.
The results of the Audit are contained on the enclosed Audit Report which outlines each
area of the City's Stormwater Program. EPA has reviewed the Audit Report which contains
required changes to the Program, which include Permit and regulatory requirements, as well is.
recommendations for program improvements. Required elements include but are not limited to
those detailed below:
A. Part I.A.(4).(b) of the Permiu..
Currently, the City's Geographic Information System (GIS) does not
include storm sewers on private property that may be connected to the
MS4, storm water management facilities, or municipal operations.
B. Parts I.A.(4).(f) and I.B.(4).(a) of the Permit:
The City has not implemented all education, training and outreach programs; i.e.,
BMP I I and. BMP 16, listed in its 2005 Stormwater Management Program
Report.
Intemet Address (URL) • http://www.apa.90v
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2
C. Part I.B.(3) of the Permit:
The City's dry weather screening and monitoring programs do not include outfalls
on private property that receive MS4 flows. In addition, these outfalls have not
been observed to determine if illicit discharges are occurring.
D. Part I.13.(4).(b) of the Permit:
The City has not provided education to all commercial pesticide, herbicide, and
fertilizer applicators in accordance with BMP13 of the 2005 Stormwater
Management Program Report.
E. Part 1.13.(4).(d) of the Permit:
The City has not enacted an ordinance addressing post -construction
controls for areas outside the Water Supply Watershed.
2. The City has not implemented BMP4 as described in the 2005 Stormwater
Management Program Report.
The City's industrial inventory does not include all industrial and
commercial entities, only those that currently hold a State of North
Carolina Industrial General Storm Water Permit (Industrial Permit).
4. The City's industrial program inspections and inspection reports are
incomplete. Compliance and enforcement are not being adequately
assessed. The City should review current procedures and develop standard
operating procedures for all industrial entities.
5. The City has not developed Storm Water Pollution Prevention Plans
(SWPPPs) for all municipally operated entities that discharge into the
MS4.
F. Part LB.(4).(e) of the Permit:
The City's construction program inspections and inspection reports are
incomplete. Compliance and enforcement are not being adequately assessed. The
City should review current procedures and develop standard operating procedures
for inspection, compliance, and enforcement.

3
G. Part I.C.3 of the Permit
The City has not produced an Annual Report for each year as required. The City's
last Annual Report was for July 2001-June 2002. The 2002 Annual Report did
not contain all information required by the Permit.
H. SWPPPs have not been developed for all municipally operated entities that hold
an Industrial Permit.
Please provide this office with a schedule of corrective actions to meet the requirements
in accordance with Part LC of the Permit. Please submit the requested information within fifteen
(15) days of receipt of this letter.
Should you have any concerns, please contact Ms. Susan Pope at [phone], or
address written comments to the address on the letterhead.
Sincerely,
David Y. Parker, Chief
Eastern Enforcement Section
Water Programs Enforcement Branch
Water Management Division
Enclosure
cc: North Carolina Department of Environment
and Natural Resources

United States Environmental Protection Agency
Region 4
Attn: David Y. Parker
Atlanta Federal Center .
61 Forsyth Street
Atlanta, Georgia 30303-8960
Re: NPDES Permit No. NCS 000247'MS4 Audit Report
(Corrective Actions Response)
Dear Mr. Parker:
Winton Salem
PublieWorks Dcpartment
Stormwater Division
City afV irwon-Ucm
Yn. Nux 2511
Winston Salem, NC 27102
Td 336.747.7480
Fax [phone]
www.cityn�s.org
The City of Winston-Salem has received the MS4 audit report and prepared the
following corrective action response for your consideration to the program components
that require attention.'United States Environmcntal Protection Agency concerns are listed
with corresponding responses below. Appendices will be included to reference
supporting documentation. Many of the concerns raised in the audit have been addressed
and others will be addressed.
Due to the limited response time, City Council approval could not be obtained for
funding needs to carry out items. Scenarios were generated to comply with EPA concerns
but will be pending City Council approval.
A. Part L A. (4). (b) of the Permit:
Currently, the City's Geographic Information System does not include storm
sewers on private property that may he connected to the MS4, stormwater
management facilities, or municipal operations.
Response: The City of Winston-Salem could not Find where this requirement was
specified in fart T. A.(4).(b), however, considering the requirements of this
activity are more prescriptively written in the draft NPDES permit to be issued,

the City of Winston-Salem intends to supplement it's existing storm sewer
inventory to comply.with this concern. a '
z The City of Winston-Salem has developed Watershed Masterplans to provide a
comprehensive evaluation of flood control and water gdMityissues within each
watershed of the City of Winston-Salem: A detailed study'of municipal storm
sewer conveyances was "initiated in 1997 and completed in 2002, Structures were =
located and a detailed list'of attribute information was recorded (see appendix A).
-'From this information, Geographical Information System (GIS) coverage was
.developed for the municipal storm sewer system. Using Areview or ArcMap, City
.,Staff can highlight any -storm sewer structure and call up an attribute table that
f; contains all of the pertinent information,on that structure or system of structures.
r• Additionally;'the.tables can be queried to run pollutant loading models or flooding "
models with XPSWIMM. However, the. storm sewer inventoryonly.•includes
structures within the City's MS4 system. The City defines its MS4 as those
structures within City rights -of -way. Specifically, this excludes systems -wholly
within private property such as large private storm sewer systems located at
shopping malls and industrial facilities. Where a storm sewer structure originates
on the public right-of-way but'then leaves the public right-of-way and crosses
private property the entire structure was located if possible.
When required in the new NPDES permit, the City expects to provide this ,
additional service. Pending City Council approval and funding appropriation, the
City of Winston-Salem will investigate and implement one of the two following
scenarios to further our existing GIS.,inventory to include storm sewers on private
property that receive,flow from the MS4,` stormwater Management facilities and
municipal operations.y.,
" Scenario l: Would include utilizing in-house field staff consisting of field
Workers and survey crews equipped with field grade GPS units to locate and
develop a GIS data set'.io denote structures`and pipes (represerited as points and
lines) without a detailed set of attributes to. identify diameter, slope, invert
elevation etc. This type of inventory would be utilized to illustrate complete
connectivity of the MS4 and -private systems that may be connected to the MS4,
however, this inventory would not contain the necessary attribute data to perform
pollutant and'flood modeling. Crews would inventory storm.sewer systems
located in private property that are connected to the MS4 that are 12 inches and.
larger with Industrial Land uses within" the watershed and 36 inches and larger for
all other land use types.Stormwater Management facilities and municipal
operations would be spatially referenced within a separate coverage; however,
inspections reports and 'maintenance records would still reside in existing excel
spreadsheets and paper files.
Scenario 2: Would requires hiring a` consultant to carry out a more "comprehensive
inventory which would include"a loeatiori team to ID/GPS the piping systems and
structures, followed up by an attributing team to gather all of the'details of the '
system. This survey grade storm sewer inventory would be conducted to sub -
meter accuracy and would inJude sufficient attribute information to utilize

XPSW1N1M for pollutant loading and flood modeling studies. The consultant
would inventory storm sewer systems that are connected to the MS4 that are 12
inches and larger with Industrial Land uses and 36 inches and larger for all other
land use types. Stormwater Management. facilities and municipal operations with
attribute data would be included in this coverage. This scenario would be
consistent with the level of detail that currently exists in the City of Winston -
.Salem Masterplanning inventory within the public right-of-way.
i
Implementation: Either scenario would require City Council approval for
funding and appropriation of funds to carryout the intended,work. In addition to
funding, land rights to.access private properties for the purpose of inventory of the
storm sewer system must be obtained.
The City Storm sewer service area is approximately 133.23 square miles with a
total watershed area draining the City of:168 square miles. It is estimated that
scenario I will take approximately 4-5 years to complete, and scenario 2 will take
approximately 6-7 years to_complete, This estimate of implementation is
referenced from the time taken to complete the existing inventory within the
public right-of-way. Scenario 2 will require consultant selection, establishing
contracts with the chosen consultant, a spend plan or lease purchase consideration
in addition to Council approval,in order to move forward into implementation.
B. Parts 1.A.(4).(Oan.4LB.(4).(a)ofthe•Permit:
The City has not implemented all education, training and outreach programs; i.e.
BMP 11 and BUP 16 listed.in its 2005 Stormwater Management Program Report.
i
Response: BMP 16 (City of Winston-Salem University) involves City staff
training citizens about different aspects of local Government including the
Stormwater Management Program and the effects of polluted stormwater runoff
in our community. A new group of citizens are trained each year on these
concepts and this BMP was carried out to completion. However in the Stormwater
Program Report there was a text error that said training was for "employees"
instead of "citizens". This text error will be corrected in the updated version of the
City of Winston-Salem Stormwater Management Program Report.
(Information regarding City of Winston-Salem University can be found in
Appendix B)
Training of City employees is geared toward field staff that is most likely to
encounter an illicit discharge while working in the field. Field staff are shown
examples of illicit discharges via video and encouraged to call the Stormwater
Division if encountered during their daily routine.
BMP I 1 (Green Business Program) involves recognizing business and industry
within the jurisdictional area, when environmentally friendly business practices
are implemented. This would include but is not limited to recognition of
business or industry on the City's website or the local Cable access channel and
signage to be located at the place of business. Stakeholder committee members

I
have been. identified and the City is moving forword to full implementation of this
program. A bcnchmarking study is currently underway to identify the successes of
other communities'who utilize this best management practice. Full
implementation of this program is expecied within the next year.
C. Part I.B. (3) of the Permit:
1
The City's dry weather screening and monitoring programs do not include
outfalls on private property' that receive MS4 flows. In addition, these outfalls
have not been observed to determine if illicit discharges are occurring.
Response: The City of Winston-Salem has conducted dry weather screening of
major outfalls that discharge to the waters of the United States as part of the
second phase.of the original permit terns: Dry weather screening of outfalls was
conducted on public and private drainage systems with land uses including:
residential (various densities), commercial; industrial and downtown business
district. Field data sheets were generated"for each major outfall which included
the location, time, drainage basin, type of conveyance land use information, visual
observations, and field analysis for temperature, ph, phenols; chlorine, copper and
detergents (see Appendix C). All inspections were conducted in dry weather
conditions with no measurable rainfall within the last 72 hours. Dry weather
screening of outfalls took.place bri public and private drainage systems..All
outfalls screened have a unique number and were photographed for later
reference. All outfalls that tested positive for a pollutant parameter were
investigated for an illicit discharge, Several illegal connections and discharges
were eliminated front this effort. T
After the outfall characterization.and screening was accomplished the City of
Winston-Salem created and implemented, the following screening and monitoring
programs to further identify, detect and eliminate additional sources of illicit
discharge to the municipal separate storm sewer system (examples of how each
program has succeed in detecting illicit activity is contained in Appendix C):
1. Water Quality Index / Non -Point Pollution Source Detection: grab samples
are obtained for pollutant parameters at 46 sites. Good water quality is crucial
for aquatic life abundance as .well as human health..One source of pollution
that degrades water quality is sanitary sewer overflows. Sanitary sewer
overflows are a frequent occurrence in any urbanized area. Often, raw sewage
enters our waterways during these overflows. Furthermore, sewer overflows
happen in remote locations and are not'discovered. The water quality
parameters are taken with instantaneous, multi -parameter meters that indicate
the possible presence of sewage as well as sediment transport, industrial
wastewater, or nonpoini source discharges in our waterways.
2. Ambient Dry Weather (conducted quarterly): 24 hour composite samples are
taken every 15 minutes by automated samplers, which are deployed at 15
sites. All pollutant paranicters are composite (except fecal coliforms - grab)

and sent to an outside, state -certified laboratoryfor analyses. A current meter
'lis utilized in order to determine flow'discharge of the stream. Pollutant
:concentrations and flow discharges are used to calculate the pollutant loading
of the waterway. Prior to any dry weather sampling event, there must be 72
hours of no rainfall.
Stream-Walking/Outfall Observation:(conducted annually): The Stormwater
Division walks every stream (no length requirement) within the city limits and
checked for various items, such as' wet pipes, illicit dischargers/connections,
.erosion, blockages, and water monitoring of unknown flows. Prior to any
stream -walking event, there must be 72 hours of no rainfall.
4. Infrared Photography (conducted in:the winter): <Salem and Brushy Forks
Watersheds were photographed at night in order to detect thermal gradient
changes in the environment. Several sources of illicit discharges were
detected and eliminated from the waterways.
Industrial General Stormwater Permit Inspections: During the inspection
process, every sormwater discharge outfall, which has the potential of
conveying pollutants on the property, is observed for contamination indicators
(for'example: sheen, odor, solids, staining, biological, and thermal). if illicit
activity is detected, the Stormwater Division ensures that the source is
permanently removed from the MS4..
D. Part I.B.(4).(b) of the Permit:
The City has not provided education to all commercial pesticide, herbicide, and
fertilizer applicators in accordance with BMP 13 of the 2005 Stormwater
Management Program Report.
Response: BMP 13 in the 2005 Stormwater Management Program Report is
directed toward best management practices with commercial facilities.
Commercial facilities are assessed for actual or potential sources of pollutants and
shown alternative practices. This BMP is. accomplished through inspection of
NPDES permitted and non -permitted facilities including but not limited to:
automotive shops, dry cleaners, fertilizer plants, battery facilities, tobacco plants,
etc. The City of Winston-Salem has specifically provided education and training
to commercial and municipal pesticide, herbicide and fertilizer applicators as a
part of this program. A targeted mailing was done to all companies the lawn care
profession which included educational information on the use of pesticides,
herbicides and fertilizers and.how these products may affect surface waters.
Presentations were also given to the association of turf grass professionals on the
status of waters in the Piedmont'and how fertilizers, pesticides and herbicides
may negatively affect water quality.
The City of Winston-Salem Vegetation Management Division applies pesticides,
herbicides and fertilizer on all City owned or maintained properties such as parks,

buildings, and right-of-ways. This facility was inspected and best management
practices were evaluated on the use of pesticides, herbicides and fertilizers.
.(Inspection report and targeted mailing information attached in appendix D)
E. Pa rt I B. (4). (d) of t4, Perm it:
1. The City has not enacted an ordinance addressing post -construction controls
for areas outside the Water Supply Watershed.
.s
Response: Requirements for,development within the Cities Water Supply
Watershed are currently housed in the Unified Development Ordinances
Technicial code which involves the City Hof Winston-Salem, the Town of
Kemersville',.the Village, of Clemnions ar dlhe Town of Lewisville.'This code sets
forth the post construction standards for development within WS III and WS IV
watersheds for the above mentioned communities. Post construction controls
outside of the water supply watershed but within the municipal limits of the City
of Winston-Salem arc carried out through the City of Winston-Salem a,
Infrastructure Development Standards. Stormwater control standards,.plan review
submittal requirements and'engirieering criteria are housed in this document.
The City of Winston-Salem is developing a Phase II post construction ordinance
(see draft ordinance in appendix E) which addresses the Phasc.II requirements.
2. The City has not implemented BMP 4 as described in the 2005 Stormwater
Management Program report.
Response: Best Management Practice 4 states that the City of Winston-Salem
will develop a procedure with the. County Health Department to' ensure proper
septic tank operations. The. City of Winston-Salem has.implemented a
departmental policy that.outlines that if Stormwater Staff encounters a failing
septic tank they will notify the Forsyth County Department of Public Health
immediately.
Contacts:
Mr. Brock Turner, DEH Septic Tank Supervisor: 703-3167
Mr. Larry Bunn, DEH_ Septic Tank Inspector:
Stormwater staff will also follow up with•the issue to ensure that it is resolved in
order to protect surface water quality.
r
This standard operating procedure is in the City of Winston-Salem' Stormwater
Division spill response manual (see Appendix E).
3. The City's Industrial inventory does not include all industrial and commercial
entities, only those that currently hold a State of North Carolina Industrial
General Storm Water,Permii (Industrial Permit)_
Response: City of Winston-Salem carries out an industrial inspection program
which audits facilities with a general or individual NPDES stormwatcr permit
issued by the State of North Carolina. These facilities are considered a high

priority because they have processes or products which may cause significant
pollution to surface waters. The City also�inspects commercial and industrial
facilities that do not have a NPDES permit when there is sufficient evidence to
believe that the facility or business in question' is contributing pollution to surface
waters.
The City of Winston-Salem has two main legal `tools' that grant.staff to Tight -of -
entry into industrial and commercial facilities: the State of North Carolina
Industrial General Stonnwatcr Permit Program (see Appendix E) and the City of
Winston-Salem Stormwater Illicit Discharge Ordinance.
The City of Winston-Salem does not have the regulatory authority to enter and
inspect a non -permitted business or facility where there is no evidence of
pollutant discharge. to surface waters..
The City of Winston-Salem will maintain an inventory of municipal landfills,
hazardous waste treatment, disposal and recovery facilities, industrial facilities
that are subject to section 313 of title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and industrial facilities that the City of
Winston-Salem determines are contributing or.have potential to contribute a
substantial pollutant loading to the municipal storm sewer'system.
This inventory will be completed within the next calendar year.
4. The City's industrial program inspections and inspection reports are
incomplete. Compliance and.enforcement are not adequately assessed. The
City should review current procedures and develop standard operating
procedures for all industrial entities.
Response: The City of Winston-Salem has developed standard operating
procedures for industrial program inspections which involve: to thoroughly
review all paperwork (i.e. SWPPP, self inspection reports economic feasibility
etc), conduct a site walkthrough; document..requirements/recommendations, send
follow-up reports and conduct re -inspections as needed to resolve issues.
The MS4 Audit report references several un-resolved items from prior
inspections. The City of Winston-Salem has implemented the following action
items to further define existing SDP's and will allow Stormwater Staff to more
effectively resolve compliance and enforcement issues for all industrial
inspections:
1. The City of Winston-Salem has recently put into service Motorola's Customer
Service Request computer software program. This computer application
specializes in tracking external and internal activities and posts reminders to
staff i f the action item is not finished by the due date. All industrial
compliance measures will be tracked electronically and provide updates, as

needed. All pertinent Stormwater Staff have been trained and are proficient in
utilizing this software package:. Traditional methods of relying on `desktop
calendars' for tracking compliance •schedules have been abandoned.
2. The Stormwater Division will commence with the issuance of compliance
schedules to all Industrial General Stormwater Permittees that possess
deficiencies. Compliance schedules -shall comprise'ofspecific due dates,
action items to be completed, notification of a time extension (applied for if
unforeseeable circumstances arise, a Notice of Violation (if warranted), .
updates of major milestones that are finished, a reinspection when all action
items have been addressed, and all relevant information of Stormwater Staff if
guidance is needed.
3. The Stormwater Division shall revisit unresolved issues from prior
industrial inspections in order to achieve compliance with all action items.
4. The Stormwater Division has evaluated the industrial inspection process for
permitted and non -permitted facilities and the compliance inspection forms in
order to create a more effective and efficient program. Carol Winston of
SAIC, gave the City of Winston-Salem several inspection form templates
(both State and Federal) thatwere utilized to create a more streamlined
inspection.form to guide the inspection process (sec Appendix E)
5. The City of Winston-Salem has developed specific inspection techniques that
are derived from the November 1998,North Carolina Division of Water
Quality's (NCDWQ) document, Stormwater Pollution Prevention Plans for
Stormwater Runoff at Industrial Activities (see Appendix E).
The City of Winston-Salem believes that,the aforementioned activities will allow
the City to inspect more facilities on an annual basis and provide better follow-up
on unresolved compliancerneasures and recommendations. The inspection
process will be more uniform for permitted and non -permitted facilities.
S.. The City has not developed Stormwater Pollution Prevention Plans
(SWPPPs) for all municipally operated entities that discharge into the MS4.
Response: The City of Winston-Salem will evaluate municipal operations that do
not currently have a Stormwater Pollution Prevention Plan. Facilities that are
contributing or that have potential to contribute substantial pollutant loading to
the municipal storm sewer system will be .11 investigated and a site specific SWPPP
will be developed.
For municipal operations that are not contributing or do not have the potential to
contribute substantial pollutant loading to the municipal storm sewer system (i.e.
recreation centers, open park land), standard operating procedures will
implemented, to at a minimum, inveritory chemicals that' are used and have
response protocols for spills of those chemicals outlined through Material Data

Safety Shects or other; appropriate information. The City will assess these
municipal operations within the next calendar year. Stormwater Pollution
Prevention Plans or SOP's will be drafted the following year.
F. Part LR(4).(e) of the Permit:
The City s construction program inspections and inspection reports are
incomplete. Compliance and enforcement are not being adequately assessed. The
City should review current procedures and develop standard operating
procedures for inspection compliance, and enforcement.
Response: "Sedimentation/Erosion Control staff has.been conducting group'site
inspections; involving all staff, institutcd,on a one day per month basis to promote
more consistent and complete site inspections and inspection reporting. Weekly
staff meetings will continue with emphasis being placed upon current compliance
and enforcement issues in order to ensure more uniform methods for resolving
common site and documentation problems.
Additional personnel will be requested iri the FY 07/08 budget. increased staffing
levels would allow for more frequent and thorough site inspections,
documentation, and enforcement follow-up.
Procedures are continually being updated to accommodate new'laws. and
regulations, new personnel, weather conditions, new erosion control methods, and
work loads.
G. Part LC.3 of the Permit.
The City has .not produced an Annual. Report for each year as required. The
City's last Annual Report was for July 2001-June 2002. The 2002 Annual Report
did not contain all the information required by the Permit.
Response: City of Winston-Salem intends to submit annual reports for each
Permit year using the State's Stormwater Management Assessment Forms (See
appendix G). Currently, information is being transferred to this form template for
submittal. A detailed annual report was submitted to the North Carolina .Division
o f Watcr Quality in 2005 outlining all of the required elements. The City of
Winston-Salem will submit annual reports to the Division as required by the
NPDES permit.
11. SWPPP's have not been developed for all municipally operated entities that
hold an Industrial Permit.
Response: Three City of Winston -Salem -owned faciltities have been issued a
State of North Carolina Industrial General Stormwatcr Permit--. Archie Elledge

Wastewater Treatment Facility, Old Salisbury Construction & Demolition.
Landfill, and the Hanes Mill Sanitary 'Land fill (please reference Appendix H).
SWPPPs have been developed an& implemented- for Ellddge WWTF and Hanes
Mill Landfill. Old Salisbury.. Construction &Demolition Landfill has been'issued
an authorization to construct permit - NCG 010000 series. This permit requires
that the owner/operator submit an erosion and sedimentation control plan to
NCDENR, Land Quality Section for approval prior to any land disturbing
activities. Once approved, the owner/operator must follow the plan without
deviation except in the.case of emergency or minor corrections. This permit does
not require the creation and implementation of a SWPPP. All other municipally
operated facilities with NPDES General Stormwater permits have a SWPPP.
If you have any questions or need any additional information, please contact me at
(336)-747-062. The City of Winston-Salem is committcd to working with the EPA and
DENR to continually improve water quality and protect the environment.
.. 1 .
t Sincerely,
/eAKf
Keith D.`Huff
Stormwater Manager
City of Wi.nston-Salem
y
CC: Mike Randall (North Carolina Division'of Water Quality)

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Winston-Salem MS4 - Municipal Operation (Streets Department City Yard) Inspection 6/29,'06
Photo 3: Leakage from the street brush.
Photo 4: Petroleum product staining to the truck parking area.

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Winston-Salem MS4 - Municipal Operation (Streets Department City Yard) Inspection 6/29/06
The spreader box washout area was upslope from a storm inlet. He directed the
department to conduct an engineering study to identify a solution to stop the spreader box
washout discharging to a storm inlet.
ssues:
No issues identified.

Winston-Salem MS4 - Municipal Operation (Streets Department City Yard) Inspection 6/29/06
Winston-Salem Municipal Operation Inspection - Streets Department City Yard
6/29/06 Weather: hot
Mr. Jerry Whittum, SAIC, and Mr. Mike Randall, Ms. Rose Pruitt, and Mr. Bill Diuguid, North
Carolina Department of Environment and Natural Resources, observed Mr. Andy Allen, Storm
Water Senior Engineering Technician, City of Winston-Salem (City), conduct a stormwater
inspection of the Streets Department City Yard municipal operation. Mr. Robert Prestwood, City
Streets Director, and Mr. Robbie Stone, City Assistant Streets Director, also joined the
inspection.
Mr. Allen conducted a very thorough inspection.
Inspector state men tslobservations:
1. Mr. Allen conducted the inspection which included interviews with Mr.. Prestwood and Mr.
Stone, review of records, and a site walk-through inspection. Due to a time limitation, the MS4
audit team requested Mr. Allen conduct the closing interview at a.later time.
2. Mr. Allen used an inspection form to document his inspection.
3. During the interviews, Mr. Allen did the following:
• Noted that the site map (dated 1983) was outdated and directed the site staff to develop a
new site map. '
• Discussed the handling of chemicals including road salt. He directed the current practice
of washing out the spreader boxes and allowing the wash water to drain to a storm inlet to
Bath Branch be changed.
• Discussed the storage of materials (e.g., soil) and directed regular yard cleaning.
• Directed site staff to implement either a weekly or bi-weekly walk-through inspection to
inspect or observe good housekeeping measures that could impact stormwater.
4. During the walk-through, Mr. Allen observed:
Multiple large petroleum product stains to the truck parking area pavement. He directed
the product to be cleaned up and better managed.
Polluted stormwater would run off from the salt dome loading/unloading area. He
directed the department to conduct an engineering study to identify a best management
practice (BMP) for the salt dome loadinglunload ing area.
An oil leak from the street brush. He directed site staff to repair the leak.

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Winston-Salem MS4 - Spencer Memorial Church 6128/06
Issues:
1. SAIC asked the inspector if he walks the entire perimeter of the site to check the silt fence.
The inspector responded that with 98 sites to be inspected he did not have adequate time to walk
the perimeter of each site. SAIC requested to see an additional outfall shown on the construction
blueprint. While walking to the area where the outfall was to be located, other areas of perimeter
silt fence, not normally inspected, were observed. Many sections of that silt fence were not
properly installed (trenched in) and were ineffective as a stormwater best management practice
(BMP) control.
2. SAIC observed that the additional outfall had not been installed. The inspector was not aware
of the additional outfall on the construction blueprint.
3 . SAIC observed that the disturbed soil area where a sewer had been installed was unstabilized
and soil disturbance had been inactive for several weeks. The inspector had previously discussed
stabilization of the area with the site representative. Reportedly, the site representative said that
until the sewer tap was approved, the area would be left unstabilized in the event the sewer
required a change. The inspector had allowed the area to remain unstabilized.
4. SAIC noted that the site had a second construction entrance that had track out to the public
street. The entrance did not have a track out pad. The inspector did not indicate a concern with
the second entrance, but may have addressed it with the site representative.

Winston-Salem MS4 - Spencer Memorial Church 6129/06
Winston-Salem Construction Inspection - Spencer Memorial Church
6/28/06 Weather: partly cloudy, hot
Mr. Jerry Whittum, SAIC, and Mr. Mike Randall, Ms. Rose Pruitt, and Mr. Bill Diuguid, North
Carolina Department of Environment and Natural Resources, observed Mr. David Evans,
Erosion Control Inspector, City of Winston-Salem (City), conduct a stormwater inspection of the
Spencer Memorial Church private construction site. Mr. Jeff Kopf, City Erosion Control
Engineer/Floodplain Manager, and Mr. Tommie Beeding, City Erosion Control Inspector, also
joined the inspection as observers. The site general contractor was on site, but did not join the
inspection.
Inspector statements/observations:
1. Mr. Evans conducted the inspection. He is responsible for inspection of 98 construction sites
in Winston-Salem and.Forsyth County. He is also responsible for other job duties such as
construction plan review.
2. Mr. Evans stated that the site contacts have been slow to respond to his directives and to
correct problems.
3. Mr. Evans led a walk-through inspection of the site. He stated that typically he does not have
the site contact walk the site with him unless he finds problems.
4. Mr. Evans observed that the silt fence had areas that were not maintained adequately.
5. Mr. Evans inspected the stormwater detention pond and outfall.
6. Mr. Evans contacted the General Contractor and brought him to areas of the site to discuss the
following stormwater concerns:
• The silt fence needs repairs at multiple locations.
• The construction site entrance needs to be refreshed.
• The stormwater detention pond has excess sediment buildup and needs to be cleaned.
• The silt fence needs to be extended to the outlet of the detention pond.
• The inactive, disturbed area where a sewer line was installed needs to be stabilized.
• Actions need to be taken to reduce the sediment entering the stormwater detention pond.

Winston-Salem MS4 - Legacy Park
Photo 7: Construction of retaining wall and filling in of detention basin (at
photo right).
6/28/06

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Winston-Salem MS4 - Legacy Park
Photo 3: Top of pipe slope drain located north of detention pond. Note the
erosion to the pipe and no BMPs to control sediment.
Photo 4: View of low area and missing silt fence. Note slope in
foreground should have been seeded and/or reseeded.
6/28/06

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Winston-Salem MS4 - Legacy Park
6/28/06
The pipe slope drain inlets did not have BMPs (e.g., silt fence) to reduce the loss of
sediment to lower site areas. Significant erosion was observed at the inlets to the pipe
slope drains.
2. The site was allowed to build a retaining wall and fill an upslope stormwater detention area
while the downslope areas were not graded and BMPs not installed as shown on the approved
plan.
3. SAIC observed that significant erosion had occurred on several site slopes.
4. SAIC observed that disturbed portions of the site appeared to have been inactive for an
unknown time and needed to be stabilized.

Winston-Salem MSA - Legacy Park 6/28/06
Winston-Salem Construction Inspection - Legacy Park
6/28/06 Weather: partly cloudy, hot
Mr. Jerry Whittum, SA1C, and Ms. Rose Pruitt, North Carolina Department of Environment and
Natural Resources, observed Mr. Tommie Beeding, Erosion Control Inspector, City of Winston-
Salem (City), conduct a stormwater inspection of the Legacy Park private construction site. Mr.
Jeff Kopf, City Erosion Control Engineer/Floodplain Manager, and Mr. David Evans, City
Erosion Control Inspector, also joined the inspection as observers. The site general contractor
did not appear to be on site. A subcontractor and crew building a retaining wall were present, but
did not join the inspection.
Inspector statements/observations:
1. Mr. Beeding conducted the inspection. He had inspected the site two days before because the
site was on his inspection schedule for that day. Mr. Beeding stated that he had directed the site
contact to correct deficiencies identified during that inspection within one week.
2. Mr. Beeding led a walk-through inspection of the site. He generally walked the perimeter of
the site.
3. Mr. Beeding observed and stated that he would direct the site contact to install the silt fence
as shown on the site plan; clean up sediment that had run off the site; reseed the slope; install
pipe slope drains as shown on the site plan; and repair the berm slopes.
4. Mr. Beeding inspected the sediment trap and stormwater detention pond from the top of the
slope.
5. Mr. Beeding discussed the retaining wall that was under construction with the subcontractor.
Issues:
1. SAIC was concerned that the site was not graded and stormwater best management practices
(BMPs) were not installed as shown on the plans as follows:
A large portion of the site was sloped to direct site stormwater around both sides of the
detention pond to a low area that was overloaded with sediment. The low area was not
designed per the site plan to accept a large portion of the site runoff. The detention pond
was dry, but the low area had standing water and extensive sediment build up.
The low area had a rip -rap filter/dam at the outfall to Salem Creek. The rip -rap filter/dam
would not likely control the discharge of sediment from the low area to Salem Creek.
A pipe slope drain that per the site plan was to direct flow to the detention pond was
placed beyond the pond and directed flow to the area of the rip -rap filter/dam outfall to
Salem Creek.

Winston-Salem MS4 - Salem Carriers
6/28/06
Photo 3..City inspectors discussing facility SPCC plan with Mr. Hutton, Salem
Carriers Shop Foreman.

Winston-Salem MS4 - Salem Carriers 6/28/06
Photo 2: Drum with spill kit next to ASTs in Photo 1.

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Winston-Salem MS4 - Salem Carriers 6/28/06
6/28/06 Weather: partly cloudy, hot
Ms. Carol Winston, Science Applications International Corporation observed Mr. Andrew Allen,
Industrial Inspector, and Mr. Keith Huff, Stormwater Manager, City of Winston-Salem (City)
conduct an industrial stormwater inspection at Salem Carriers. Neither Mr. Allen nor Mr. Huff
had previously inspected this facility. Salem Carriers is covered under the North Carolina
General Permit for Storm Water Discharges associated with industrial activities. The City
typically notifies an industrial facility prior to conducting a stormwater inspection, but did not
pre -notify Salem Carriers. Upon entry to the facility, Mr. Huff and Mr. Allen introduced
themselves and explained the purpose of the inspection to Mr. Skinner, Facilities Director. Mr.
Skinner indicated that he needed to contact corporate staff to determine whether the inspection
could proceed. Mr. Skinner contacted Mr. Tom Sides, the Safety Director, who after discussions
via the phone with Mr. Skinner and Mr. Huff, indicated that the inspection could proceed.
While waiting for a facility representative who could accompany the MS4 audit team on the site
inspection, the City inspectors inquired about the facility operations. Mr. Skinner indicated that
the facility had transportation/hauling operations of mostly clothing and general merchandise.
The facility performs vehicle maintenance inside and has aboveground storage tanks (ASTs)
outside. The City inspectors requested a copy of the facility Spill Prevention Control and
Countermeasures (SPCC) Plan. After a brief wait, the MS4 audit team decided to conduct a
quick walk-through of the facility because of time constraints.
Inspector statements/observations:
1. Mr. Allen first inspected the ASTs. He inquired about the fueling process and availability of
spill kits. He observed the spill kits located next to the tanks.
2. Mr. Allen asked review the SPCC Plan. When he was provided with the SPCC Plan, Mr.
Allen reviewed the site drainage map and asked numerous questions about the SPCC Plan,
facility documentation, and the facility operations (e.g., site drainage, vehicle maintenance
activities, whether the drain with the oil -separator discharged to the wastewater system or storm
sewer).
The inspection was ended because of time constraints.
Issues:
None. The City inspectors handled this situation, which was not their normal inspection process
(i.e., pre -notification of the facility to be inspected), very professionally. Also the inspectors
conduct extremely thorough inspections of industrial facilities.

(2) ensure that issued permits have the date of issuance and that the Financial Responsibility
forms have complete contractor information.
(3) in general, increase the frequency of inspections to inspect each construction site at least bi-
weekly.
(4) evaluate whether additional inspectors should be hired to conduct adequate and thorough
inspections at the frequency needed for an effective program.
(a) establish a schedule for the supervisor of the City inspectors to periodically accompany the
inspectors on construction site inspections to evaluate their effectiveness and provide one-on-one
training as necessary.
(6) develop enforcement procedures or an enforcement response plan which describes different
types of deficiencies (e.g., areas of downed silt fence compared to inadequate protection of
disturbed areas near a stream) and escalated enforcement actions based on the types of violation
and continuing noncompliance.
(7) ensure that the erosion control inspectors receive adequate/formal training on erosion
control measures and inspections on a regularly scheduled basis.
(8) develop a formal program to provide outreach and training for construction site operators.
2.8 Pollution Prevention/Good Housekeeping for Municipal Operations [Permit
Sections I.13.(4)(b) and I.B.(4)(d)]
2.8.11 Inspections and report generation of City -owned facilities and municipal operations
The Stormwater Division developed a list of City -owned municipal operations from an existing
City Property Department list. The Stormwater Division is in the process of interviewing staff
from each City Department to identify all municipal operations that should be inspected for
stormwater concerns. The City has approximately 18 municipal operations of which many have
multiple locations throughout the City. The Stormwater Division has inspected six City
municipal operations and anticipates it will take approximately four years to inspect the
remaining municipal operations. The MS4 audit team accompanied the Stormwater Division as
they inspected the Streets Division municipal operation (see Appendix D). The Stormwater
Division conducted a very thorough inspection and provided good directives to the municipal
operations representative to address stormwater concerns. The MS4 audit team noted that
several other municipal operations (e.g., Sanitation Division) were co -located on the site. The
Stormwater Division's current practice is to individually inspect each municipal operation even if
several City departments are co -located on a site. The municipal operation inspections are
documented with an inspection report. The Stormwater Division has reinspected some sites to
ensure identified concerns were corrected.
The municipal operations do not have Stormwater Pollution Prevention Plans (SWPPPs) to
provide Stormwater guidance to municipal operations staff.
Required actions: None.
September 28, 2006 17 Draft Report

Recommended actions: The Stormwater Division should-
(1) evaluate means to expedite (a) identifying which municipal operations are "major, " which
are "minor, " and which do not have stormwater concerns and (b) conducting inspections to
complete all municipal operation inspections within the next year. The Stormwater Division may
choose to expedite the inspection process by inspecting all municipal operations co -located at a
single site and then preparing one report that is sectioned according to the municipal
operations. The report should than be provided to all represented municipal operations for
review of the applicable section. Use of a single, combined report would also provide
stormwater training to the other municipal operations if they read about the stormwater
concerns identified for the co -located municipal operations.
(2) develop and implement an SWPPP for all major municipal operations and possibly develop a
universal SWPPP for all the minor municipal operations.
2.8.2 Training
BMP 2 (Training of employees) in Section 7.6.1 of the 2005 Stormwater Management Program
Report states that employees will be trained on pollution prevention and good housekeeping
techniques specific to their respective operation. The Stormwater Division staff provide
stormwater training to staff of other City divisions following the municipal operation inspections
of their respective sites. The training is both general (e.g., to direct staff to observe for
stormwater concerns as they travel about the City) and site -specific (i.e., related to concerns for
the municipal operation where employed). The training is not mandatory and may not be
attended by all pertinent staff. The Stormwater Division anticipates approximately four years
before all municipal operations are inspected; thus several years may pass before all appropriate
City staff have an opportunity to receive stormwater training and even longer before refresher
training is available.
BMP 16 (City of Winston-Salem University) in Section 7.1.1 of the 2005 Stormwater
Management Program Report states that training will be provided for all new employees. The
City does not provide stormwater training to newly -hired employees. The Stormwater Division
staff stated that this BMP was intended for the general public, not City employees, and that the
2005 Stormwater Management Program Report would be amended to reflect that information.
Required actions: None.
Recommended actions: The City should:
(1) revise the procedure to train City staff as soon as possible rather than waiting until their
respective municipal operation has been inspected. An escalated training schedule will
potentially improve the handling ofstormwater at municipal operations prior to an inspection
occurring.
(3) ensure that all pertinent City staff (e.g., staff that regularly travel the streets of the City)
receive stormwater training when hired and at a minimum bi-annually.
September 28, 2006 18 Draft Report

(4) update BMP 16 in Section 7.1.1 of the 2005 Stormwater Management Program Report to
ensure that it contains an accurate and current list of the City's program implementation
activities. In addition, this proposed change to its stormwater program must be adequately
described and justified in the City's annual report in accordance with Section LC.(3)(b) of
Permit No. NCS000247.
2.8.3 Maintenance and Inspections
BMP 1 (Inspection and report generation of City -owned facilities and municipal operations to
determine structural and non-structural BMPs) in Section 7.6.1 of the 2005 Stormwater
Management Program Report states that City -owned or operated facilities will be inspected for
pollution prevention and good housekeeping practices and an inspection report generated with
suggested pollution prevention measures and techniques. The City has five municipal BMP
structures which include one bioretention cell, three constructed wetlands, and one created
floodplain. The City MS4 include open drainage swales, inlets, catch basins, and storm sewers.
The ,Stormwater Division is inspecting the City -owned facilities and municipal operations (see
Section 2.8.1 above) and generating inspection reports. Various City divisions (e.g., Streets
Division) conduct scheduled inspections and maintenance of the MS4 components and keep
records of the inspections.
Required actions: None.
Recommended actions: None.
2.8.4 Yard Waste Program
The City has an ongoing yard waste collection program that operates year-round. Collected yard
waste includes grass clippings, brush, leaves, and Christmas trees. The City provides collection
from each neighborhood every other week. Homeowners can purchase 96-gallon yard waste
containers for grass clippings, leaves, and small branches. Large quantities of leaves and brush
are to be piled at the curb, but are prohibited from being placed on City streets. The City tracks
the tons of yard waste collected annually.
Required actions: None.
Recommender! actions: None.
2.8.5 Recycling Program
The City has an ongoing curbside recycling program that provides weekly collection from single
and multi -family homes and small businesses. Items collected in the curbside recycling include
newspapers, magazines, telephone books, office paper, paperboard, cardboard, aluminum and
steel cans, Nos. 1 and 2 plastic bottles, and clear, green, and brown glass. The recycling program
September 28, 2006 19 Draft Report

is operated by a private contractor. The City has nine cardboard drop-off sites located throughout
the City. The City tracks the tons of recycled material collected annually. Bilingual recycling
guides are produced and distributed through various means.
The City has an annual white goods curbside collection. City and county residents are allowed to
drop off white goods at the Hanes Mill Road Landfill after paying a tipping fee. The white goods
and used tires are recycled.
Required actions: None.
Recommended actions: None.
2.8.6 Public Street and Roadway Maintenance
The City has a snow and ice management program that includes plowing and salt and sand
addition. The Streets Division has standard operating procedures (SOPs) for salt addition. The
salt and sand mixture is typically only used on intersections. If the accumulation of sand appears
heavy, the area is swept. The truck salt boxes are washed out at the Streets Division yard (See
municipal operation inspection in Appendix D). The City used brine application for the control
of ice as a trial over the past two winters.
The City operates an ongoing street sweeping program that uses a light spray wet sweep process.
City areas are defined as light, medium, and heavy debris areas, and street sweeping occurs three
times, four times, and five times annually respectively. The City central business district streets
are swept every two weeks. The collected debris is disposed at the Hanes Mill Road Landfill.
The City tracks the tons of debris collected and evaluates the effectiveness. of the program.
The Streets Division performs roadway maintenance of the City's paved and gravel streets. The
roadway maintenance includes pothole repairs, skin patching, tar and chip, and street base repair.
Following street base repair, most street resurfacing is conducted by a City contractor. City
contracts for the Streets Division do not typically include a requirement for stormwater BMPs.
The City allows utilities to conduct cuts of City streets, but the Streets Divisions makes all
repairs and bills the repair cost to the utility. The NCDOT has the responsibility for several
miles of State-owned streets and roadways within the City.
Required actions: None.
Recommended actions: The City should ensure that upcoming contracts for roadway
maintenance include appropriate stormwater BMPs (e.g., protection of street inlets).
September 28, 2006 20 Draft Report

2.8.7 Pesticide, Herbicide, and Fertilizer (PHF) Application
The City has an ongoing pesticide, herbicide, and fertilizer (PHF) application program. The City
has developed and implements SOPS for PHF spray tank filling and rinse operations. The City
keeps a manual of material safety data sheets (MSDS) and product labels in each vehicle that is
used for chemical transport. Restricted use pesticides are occasionally used by the City. The
City also utilizes, but is not very active, in incorporating integrated pest management (IPM) into
its procedures. The City tracks the amount of PHF chemical application through the City work
order system.
The City uses contractors to conduct fertilizer application to two soccer complexes, some right-
of-way mowing, and concrete medium maintenance. The contractors must have a pesticide
license prior to award of the contracts. The City does not require the implementation of
stormwater BMPs for PHF applicator contractors.
Required actions: None.
Recommended actions: The City should ensure that upcoming contracts for PHF application
include stormwater BMP requirements.
2.9 Monitoring Program [Permit Sections I.B.(1), I.B.(5), and I.B.(6)]
The City's initial monitoring efforts focused on characterization monitoring. After the City had
obtained and analyzed the required twelve samples per Permit Section 1.13.(1), the City stopped
this type of monitoring after discussions with the NCDENR. The City then started to implement
an in -stream ambient monitoring program. The City provided a document to the MS4 audit team
which contains an overview of the City's Stormwater Division Sampling Program. The City's
in -stream monitoring includes:
• Dry weather quarterly monitoring [BMP 4 (Ambient Sampling) in Section 7.3.1 of the
2005 Stormwater Management Program Report]: 24-hour composite sampling at 15 sites
is performed over the course of a week. Pollutant concentrations and flow discharges are
used to calculate the loading of the waterway.
• Wet weather annual monitoring [BMP 5 (Storm Event Sampling) in Section 7.3.1 of the
2005 Stormwater Management Program Report]: Automated sequential samplers are
placed at the same 15 sites at which dry weather quarterly monitoring is conducted during
a representative storm event. Pollutant concentrations and flow discharges are used to
calculate the loading of the waterway.
Water quality index and SSO detection: Grab samples are collected monthly at 22 sites
for the water quality index pollutants and 46 sites for the SSO detection (as listed in the
City's Monitoring Program document).
The City's documentation of its monitoring program includes the analytical results; date and
duration in hours of the storm event sampled and the end of the previous measurable storm event
September 28, 2006 21 Draft Report

(i.e., 72 hours without any measurable rainfall); rainfall measurements or estimates of the storm
event which generated the sample runoff, and estimate of the flow of the discharge sampled.
Monitoring results are being reviewed to determine if they can identify and discern trends in
water quality improvement. They have developed graphics to assist the evaluation. However,
the City has experienced drought conditions within the past several years, so assessment of the
monitoring data is difficult. Basically the City is attempting to get a good data set to review, but
consider themselves in the early stages of this process. City staff cannot state with any degree of
certainty how the stormwater program activities are impacting water quality. Mr. Huff indicated
that all the Phase 1 MS4s in the State meeting within the next couple of months to discuss their
monitoring programs. The goal is to develop a uniform protocol and sampling program for the
State's consideration for the next permit.
Required actions: None.
Recommended action: The City should move forward in discussions with other Phase I MS4s in
the State and in discussions with the State regarding changes to its monitoring program for the
upcoming permit.
2.10 Annual Report [Permit Section LC.(3)]
Per Section I.C.3 of Permit No. NCS000247, the City must submit the specified reporting and
monitoring information annually. Mr. Huff provided to the MS4 audit team a copy of the most
recent Annual Report which could be found; it was dated August I, 2002 (2002 Annual Report).
In addition, he provided a copy of the City Stormwater Division FY 04/05 Workplan (FY 04/05
Workplan), which he thought might include some descriptions of the items required in the
Annual Report. The FY 04/05 Workplan includes a detailed list of activities and implementation
schedule for the following stormwater components: Public Education and Awareness, Public.
Participation, Pollution Prevention, Field Operations, Administration, Pollutant Loading, and
Stormwater Billing.
It does not appear that the City has submitted an annual report in accordance with Permit Section
I.C.3 since August 2002. In addition, the following items required by the permit were not
included in the 2002 Annual Report:
• Detailed descriptions of the status of implementing all program components. The 2002
Annual Report is missing information on development and re -development, erosion and
sediment control program, municipal operations.
• A description and justification for proposed changes to Stormwater Program.
• Information on annual expenditures and budget anticipated for the year following each
report along with an assessment of the continued financial support for the overall
Stormwater Program. The 2002 Annual Report discusses the utility fee increases, but
does not include information on annual expenditures and anticipated budget.
• Summary of activities including inspections, maintenance and enforcement actions, etc.
September 28, 2006 22 Draft Report

• Information concerning areas of water quality improvement. The 2002 Annual Report
discusses the monitoring activities to detect water quality improvements, but nothing
about the results of such monitoring.
Required action: Per Section I. C(3) of Permit No. NCS000247, the City must submit an annual
report by August 31st of each year which covers the previousyear's activities from July 1st
through .June 301h. The annual report must include all the required items listed in Sections
I C(3)(a) through (g) in its annual report.
Recommended actions: None.
2.11 Budget and Resources [Permit Section LA(4)(e)]
The City established a stormwater utility to fund its stormwater program. The City was
proposing to increase its stormwater annual fees as follows:
• Residential - $51 per residential parcel (increased from $49).
• Nonresidential - $487 per impervious acre (increased from $359 per impervious acre).
These fees were enacted after the MS4 audit. .
The increased fees were for the City to replace aging and undersized stormwater infrastructure.
The proposed increase would allow for $900,000 in stormwater capital projects (i.e., drainage
projects).
Mr. Huff provided a copy of the City's budget allocations for the various stormwater program
components using the revenue generated from the stormwater utility fees. The approximate
funding amounts allocated to the various stormwater program components were as follows:
• Administration/NPDES Compliance - $963,000
• Water Quality - $428,000
• Public Education - $77,000
• Drainage Maintenance - $2,421,000
• Seasonal Leaf Collection - $1,199,000
• Street Sweeping - $366,000
• Capital Projects Reserve - $778,000
• Vector Control - $20,000.
Other stormwater program components such as the construction site runoff control (erosion
control) program are funded through different mechanisms (e.g., permit fees).
Required actions: None.
Recommended action: The City should evaluate and ensure that stormwater program
components have adequate funding and staff resources for program implementation.
September 28, 2006 23 Draft Report

Summary of Public Education/Public Involvement Activities
BMPs from
Status of Activities
2005 Stormwater Management
Program Report
BMP 1 (7.1.1) -Participate with
The Piedmont Triad Water Quality Partnership is an organization of 17 communities
Piedmont Triad Water Quality
(all the Phase I1 communities in Forsyth County), which is focused on public
Partnership
education related to water quality issues. The organization has a website
(w%i-A,.piedmontwaterquality.org). The public education activities implemented by the
organization included (1) developing a brochure for distribution titled Protecting
Water Quality and translation of the brochure into Spanish (2) printing of general
information; (3) posting of watershed signs, and (4) airing television advertisements
on pet wastes and fertilizers.
• The Partnership obtained a $95,000 grant to replicate a Florida program called Clean
Yards and Neighborhoods, which is being implemented with the North Carolina
Cooperative Extension. The program includes workshops which focus on stormwater
runoff and protecting water quality through proper yard maintenance practices. if this
program is successful, it will be implemented State-wide.
• Ms. L'Esperance co-chairs the Partnership.
BMP 2 (7.1.1) - Website
Ms. L'Esperance is responsible for the City's stormwater website
(www.stormwatersmart.com). In June 2006, the City went on-line with a new
stormwater website which is consistent with the overall City website.
• The website includes, among other items, a listing of scheduled events, descriptions of
the City's volunteer programs (e.g., Adapt -A -Stream, Storm Drain Marking),
stormwater BMPs for businesses, and steps for homeowners to protect water quality.
BMP 3 (7.1.1) - Website promotion
The website has been promoted through advertisements on City buses. However, Ms.
L'Esperance is not sure that this will continue because of the high costs.
• Ms. L'Esperance tracks the number of hits on this website.

Summary of Public Education/Public Involvement Activities
BMPs from
Status of Activities
2005 Stormwater Management
Program Report
BMP 4 (7.1.1) and BMP 12 (7.3.1)
The City has numerous educational materials and brochures that it distributes. Ms.
- Educational Information
L'Esperance provided a list of28 different brochures distributed by the City (two
brochures also in Spanish). For example, the City distributed 6,000 brochures titled
Protecting Water Quality, 5000 brochures titled Rain can be a pain in the drain, and
2,000 stormwater door hangers (in English and Spanish).
BMP 5 (7.1.1) Presentations
Ms. L'Esperance has given numerous presentations within the past few years. She
provided a summary of presentations which included the following number of youth
presentations: 43 in 2003, 23 in 2004, 34 in 2005, and 25 in 2006 (through June).
• The City maintains a record of the location and number of attendees for each
presentation. The following were included among the presentations in 2006:
— Carver High School (March 9 and 10, 2006) - 50 attendees
— Clubhouse (March 2, 2006) - 30 attendees.
BMP 6 (7.1.1) - Community
The City participates in the following community events:
Events
— Street fairs such as the Dixie Classic Fair (almost State-wide), Hispanic Fair
(City-wide), and the Earth Day Fair (City-wide)
— Volunteer fairs held at Wake Forest University, Winston-Salem State
University and churches and
— Neighborhood events.
• At these events, City staff distribute brochures and other gifts (e.g., key chains, pens,
decals that look like storm drain markers, tee-shirts).
• The City documents the number of items distributed. - For example, the City
documented that it had 500 giveaways at the Earth Day Fair held on April 22, 2006.

Summary of Public Education/Public Involvement Activities
BMPs. from Status of Activities
2005 Stormwater Management
Program Report
BMP 8 (7.1.1) - Riparian Buffer The City completed stream bank restoration projects in City parks to increase
campaign awareness. Signs displayed at the parks show before and after pictures to allow
residents to gain an understanding of the project benefits. In addition, "No Mow"
signs are placed along riparian buffers in City parks.
• The City posted stream management and restoration manuals on its website to give
residents information on how to better manage streams and riparian areas.
• An example project is the Civitan Park Stream Bank Restoration, which involves re-
establishing the stream channel to a healthy naturally stable stream system over the
long term. This project includes activities such as restoring the stream channel,
repairing steep slopes using soil fabric lifts, creating riparian buffers using native
vegetation, and constructing wetlands for stormwater runoff treatment.
• The City developed and distributed an outreach fact sheet on this project.

Summary of Public Education/Public involvement Activities
BMPs from
2005 Stormwater Management
Program Report
Status of Activities
BMP 9 (7.1.1) - School Outreach;
The City has various types of materials and educational activities which are
BMP 3) (7.2.1) - Mud Puppy Pond;
specifically tailored to different school -age groups. Examples of age -appropriate
BMP 5 (7.2.1) - School and Camp
activities include
Programs;
— Elementary school students: Verde Frog activity which simulates pollutants
BMP 10 (7.2.1) - Poster Contest
that are discharged to the environment; charts with stickers for marking
household hazardous wastes; water cycle poster; City Page activity sheet
(maze); and finger puppets.
— Middle school students: Ms. L'Esperance works with 8th grade teachers to
incorporate water quality topics into their curriculum. For these activities, she
works individually with the teachers who are interested.
— High School students: Short list of important water legislation; vocabulary list;
Stormwater Runoff Challenge; handouts; and playing cards from the
Groundwater Foundation with trivial pursuit -type questions.
• The City conducts a number of school programs/camps at the recreation centers and
the Winston-Salem Science Center. For example, on May 12, 2006, the City
conducted a "creek crawl" at the Sedge Garden Recreation Center. Eleven children
participated.
• The first poster contest, held in the spring semester of 2005 (late spring), was
coordinated by the Council of Governments. There were at least 50 entries from the
Winston-Salem schools. The second poster contest, scheduled for the fall semester
2006, will focus on the Winston-Salem schools.
• Ms. L'Esperance documents all the school outreach activities conducted. Through
.tune 2006, the City has conducted 25 youth (school -age) presentations.
4

Summary of Public Education/Public Involvement Activities
BMPs from Status of Activities
2005 Stormwater Management
Program Report
BMP 10 (7.1.1) - Hispanic The City's initial outreach began in late 2003 as a cooperative effort between the
Outreach Campaign and BMP 6 Cities of Winston-Salem and Greensboro. The campaign included the distribution of
(7.2.1) Recruit Hispanic Volunteers materials available from EPA and an advertising campaign developed for Que Pasa
media, which included newspaper and radio advertisements.
• Other early program components included translation and redesign of a door hanger
with English on one side and Spanish on the other side; new -storm. drain markers with
the hotline number and marked "No Dumping - Drains to Creek" in Spanish; general
stotmwater informational brochure translated into Spanish; and a business brochure
translated into Spanish.
• Brochures were distributed to area libraries and at the following events/locations:
Dixie Classic Fair and Hispanic Festival, Kennedy Middle School and Forsyth Tech
Hispanic Center, YMCA Community Outreach Services, area recreation centers, and
businesses.
• Presentations were conducted at the after school program at the Salvation Army
facility, which served Hispanic children, with information for Hispanic parents.
• The City received a grant through the Northwest Piedmont Council of governments
for Hispanic outreach. Through this grant, the City met with Hispanic community
leaders and distributed brochures through various Hispanic organizations and
communities.
• The City submitted a grant proposal to the NCDENR for a stormwater education
program targeting the Hispanic population in Winston-Salem. The purpose of the
grant is to train new instructors that will create and implement a communications
campaign targeted to Hispanics in the Winston-Salem area. Basically the grant will
fund a train -the -trainer program in which they provide a stipend to bilingual speakers.

Summary of Public Education/Public Involvement Activities
BMPs from Status of Activities
2005 Stormwater Management
Program Report
BMP 10 (7.1.1) - Hispanic The City planned to recruit Hispanic volunteers with the first grant they received.
Outreach Campaign and BMP 6 They were successful in recruiting some groups who did storm drain markings.
(7.2.1) Recruit Hispanic Volunteers Ms. L'Esperance noted that recruitment is difficult because many Hispanics have two
(continued) jobs and language is a barrier. The new grant proposal will focus on methods for
recruiting volunteers.
BMP 11 (7.1.1) - Green Business The City has not yet developed its Green Business program. Ms. L'Esperance stated
Program that one concept for the program is that businesses that are considered "green" will be
posted on the City's website and be given a certificate. However, the City is currently
conducting research to develop this program and to determine whether it will include
other environmental areas in addition to stormwater.
0

Summary of Public Education/Public Involvement Activities
BMPs from
Status of Activities
2005 Stormwater Management
Program Report
BMP 12 (7.1.1) -Municipal Good
The City conducts stormwater municipal good housekeeping training for its
Housekeeping Training and
employees. Ms. L'Esperance provided a copy of the description of the training and
Education
the quiz which employees must take. It appears that the training is a brief overview
(about 45-minutes to one -hour session) of stormwater issues and BMPs which apply
to municipal operations.
• According to the summary of 2006 activities, the municipal good housekeeping
training was presented to:
— 19 Vegetation Management employees on January 4 and 5, 2006
— 38 Parks and Recreation employees on January 1 1, 2006
— 45 Utilities (Construction &Maintenance) employees on February 21 and 23,
2006
— 70 Public Safety employees on June 16, 2006.
• The training also includes viewing of a video titled Storm Water Municipal Pollution
Prevention Best Management Practices, which the City purchased.
BMP 15 (7.1.1) - Big Sweep and
The City's Big Sweep is part of the North Carolina Big Sweep (conducted nationally)
BMP 2 (7.2.1) - Big Sweep
to clean up local waterways and of the Keep Winston-Salem Beautiful program.
• Volunteers can sign up to assist in cleaning up local streams and lakes.
• The Big Sweep event is scheduled for Fall 2006.
BMP 16 (7.1.1) - City of Winston-
The City University involves a course which teaches citizens everything about
Salem University
municipal government. It began as a grant about three years ago. Citizens are
encouraged to submit applications to attend the course, which.is.given about once per
year with about 25 attendees.

Summary of Public Education/Public Involvement Activities
BMPs from
2005 Stormwater Management
Program Report
Status of Activities
BMP 1 (7.2.1) - Adopt -A -Stream
This program involves groups signing up to perform a minimum of two clean-ups per
Program
year at assigned stream reaches. The City assesses and assigns the streams to the
volunteer group. City staff accompany the group on their first clean-up if possible.
• The City promotes the program through an ongoing advertisement in the Journal
promoting this program, on the City's website, in the City's basic brochure, and
during presentations. For example, the City gave an Adopt -A -Stream presentation to
the Hope Presbyterian Youth Group on February 26, 2006.
• Adopt -A -Stream is a cooperative program with Keep Winston-Salem Beautiful.
• Clean-up reports are prepared by the volunteer group and sent to the City and the
Keep Winston-Salem Beautiful program.
• The City currently has 19 groups committed to the Adopt -A -Stream program.
According to the City records, in 2005, the 19 groups involved 630 volunteers and
collected an estimated 35,855 pounds of waste/debris.
BMP 4 (7.2.1) - Creek Crawls
The target audience for the Creek Crawl program is primarily high school students.
Ms. UEsperance promotes the program through communication with teachers.
• Typically, the program first involves a presentation. Then the students are taken out
into the field where they walk along and observe the creek or stream. Also, field
parameters are tested including pH, ammonia, conductivity, and turbidity.
• During Spring 2006, the City conducted two Creek Crawls.

Summary of Public Education/Public Involvement Activities
BMPs from Status of Activities
2005 Stormwater Management
Program Report
BMP 7 (7.2.1) - Storm Drain The City promotes the storm drain marking program while conducting presentations
Marking and at -community events and volunteer fairs.
• The City documented placement of 150 markers in 2003, 260 markers in 2004, 430
markers in 2005, and 75 markers through June 2006. Ms. L'Esperance noted that the
markers are often vandalized.
• In 2004, the program expanded to include the distribution of informational door
hangers in the same areas where the storm drains are being marked.
BMP 9 (7.2.1) - Training The City conducted a BMP workshop in the Spring 2006.
Workshops Ms. L'Esperance sent a letter dated February 8, 2006, to a list of developers regarding
a training seminar held on March 16th and 17th covering the review of design and
implementation of Stormwater Best Management Practices which will be used to meet
the NPDES Phase I1 requirements.
E

Winston-Salem MS4 - Hanes Facility 6/28/06
Winston-Salem Industrial Inspection - Hanes Facility
6/28/06 Weather: partly cloudy, hot
Ms. Carol Winston, Science Applications International Corporation observed Mr. Andrew Allen,
Industrial Inspector, and Mr. Keith Huff, Stormwater Manager, City of Winston-Salem (City)
conduct an industrial stormwater inspection at the Hanes facility. Both Mr. Allen and Mr. Huff
conduct inspections at the Hanes facility. Mr. Larry Lickbar, Environmental Coordinator for
Hanes, accompanied the MS4 audit team. The Hanes facility is covered under the North
Carolina General Permit for Storm Water Discharges associated with industrial activities.
Because of time constraints, Mr. Allen and Mr. Huff were directed to perform an abbreviated
version of their normal inspection process and only perform an inspection of the outside areas
and outfalls.
Inspector statements/observations:
1. Mr. Allen and Mr. Huff began the inspection. They inspected a waste bin for crushed metal
barrels/drums. Mr. Allen noted that the bin was not covered and had rusted out holes. lie
explained to the facility staff that it was important that the bin be covered and in good condition.
Pie also noted rainwater in the crushed barrels.
2. Mr. Allen then proceeded to the storm sewer access point. He discussed the use of the white
tube to plug the storm sewer line in the event of a spill at the Hanes facility.
3. Mr. Allen observed the dry loading area and the storm drain in this area. He observed trash in
the area. He discussed the clean-up procedures and the unloading process with the Hanes
representative.
4. Mr. Allen observed two other loading docks and also a covered drain in the loading dock area.
There was gray fabric in and around this storm drain. He told the Hanes representative that this
area needed to be cleaned up and maintained.
5. Mr. Allen asked about the sprinkler system and whether biocides or rust inhibitors were used.
The Hanes representative noted that antifreeze is used in the air conditioner unit on the roof, and
in the event of a spill, the spilled material would enter the roof leaders. Hanes staff have access
to spill kits. Also the pipe is constructed in short sections so if they break, only a small amount
of material will be spilled. Mr. Allen discussed spill training for employees with the Hanes
representative.
6. Mr. Allen observed the bulk chemical off-loading area. A drain used to catch wash water or
spills from the bulk chemical off-loading area previously discharged to the storm sewer, but now
goes to the wastewater system.
7. Mr. Allen discussed with Mr. Lickbar whether a Hanes representative is present during the

Winston-Salem MS4 - Hanes Facility 6/28/06
off-loading process and asked about the cleanup process after off-loading is complete. Mr.
Lickbar stated that the area is washed down after off-loading. The wash water enters the drain,
which is now piped to the wastewater system. Mr. Allen conducted a thorough inspection of the
off-loading area, the pipe connections, and the buckets under the pipe connections for drips,
leaks, etc.
8. Mr. Allen next inspected the drum washing area, which Mr. Lickbar stated is no longer in use.
Mr. Allen observed an open drum containing some wax -like compound. Mr. Lickbar did not
know what was in the drum, and Mr. Allen asked that the drum be removed.
9. Mr. Allen observed two aboveground storage tanks (ASTs) with secondary containment.
Rainwater pumped from the secondary containment is discharged to the wastewater system. Mr.
Lickbar noted that a Hanes representative is usually present when the rainwater is being pumped.
Also if Hanes staff notice a leak in the hose, the hose is replaced.
10. Mr. Allen observed some spent absorbent socks, downslope from the ASTs. He requested
that these be removed, and Mr. Lickbar took immediate action to have them removed.
11. Mr. Allen inspected the pallet storage area and a nearby dumpster which appeared to have
sanitary waste (e.g., food).
12. Mr. Allen inspected the fly ash storage area and two nearby dumpsters. He inquired about
clean-up procedures for this area. Mr. Lickbar indicated that a maintenance contractor cleans up
the area, but was not aware of their schedule. Stormwater runoff from this area would go to a
drain which goes to the wastewater system.
13. Mr. Allen noted some empty drums and recommended that they be covered.
14. Mr. Allen asked Mr. Lickbar about a tank with piping, which he had also asked about during
the previous inspection of the Hanes facility. Mr. Lickbar did not know what had been stored in
the tank or its use, but indicated that he would find out and contact Mr. Allen with the
information.
15. Mr. Allen observed an AST under cover with secondary containment. An uncovered bucket,
which was three-quarters full of water and an unknown liquid, was sitting next to this tank. Mr.
Allen recommended that Mr. Lickbar address this bucket (e.g., dispose of the material
appropriately and keep covered when in use).
16. The MS4 audit team observed an off -site stormwater outfall which discharges to a stream
that is spring -fed. Mr. Lickbar indicated that the Hanes guard performs a visual inspection twice
per day of this discharge.
17. The MS4 audit team also observed a storm sewer line inside the building. There were two
pipes entering the line. The flow from one line was stormwater from oft -site the Hanes facility

Winston-Salem MS4 -Hanes Facility
6/28/06
(i.e., Buxton Street), but it was not certain from where the flow in the second pipe was coming.
Mr. Allen and Mr. Lickbar discussed a few possibilities such as the parking lot or condensate.
The flow had a slight film and some particulates. Mr. Lickbar indicated that he would
investigate this flow and get back to the City.
At this point, the inspection was ended because of time restraints.
Issues:
None, The City inspectors conduct extremely thorough inspections of industrial facilities.

Winston-Salem MS4 - Hanes Facility
Photo l: Waste bin for crushed barrels/drums. Note
rust holes on side of waste bin.
6/28/06

Winston-Salem MS4 - Hanes Facility
6/28/06
Photo 2: Storm sewer access point. White tube is an inflatable seal used for the
storm sewer pipe in the event of a spill.
Photo 3: Loading docks.

m
.�ii ? '}�'1 � � - ''f%��ra :.,"`� ;; a #'l,-r'n?��d`,. ��.,i:ik°%m', ae `s�*P.
4, �:! •' , ��t��:�;� ; ,? ��':

Winston-Salem MS4 - Hanes Facility
6/28/06
Photo 6: Drain to.catch wash water from bulk chemical off-loading area. Drain
previously connected to storm sewer, but now is collected to sanitary sewer,
Photo 7: Chemical off-loading area with pipe connections. Area is sloped toward
drain in Photo 6.

Winston-Salem MS4 - Hanes Facility
Photo 12: Used pallets. Inspector noted residue on and around the pallets.
6/28/06

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Winston-Salem MS4 - Hanes Facility 6/28/06
Photo 15: Covered aboveground storage tank with
secondary containment. Note uncovered bucket three-
quarters full with water and unknown liquid.

Municipal Separate Storm Sewer System (MS4) Audit
Winston-Salem, North Carolina
June 27 - 29, 2006
Prepared for:
EPA Region 4
61 Forsyth Street, S.W.
Atlanta, GA 30303-8960
Prepared by:
Science Applications International Corporation
11251 Roger Bacon Drive
Reston, VA 20190

4
Table of Contents
I. INTRODUCTION............................................................ 1
2. FINDINGS.................................................................. 1
2.1 General Findings....................................................... 1
2.2 Public Education and Outreach Program/Public Involvement and Participation [Permit
Sections I.A.(4)(f) and I.B.(4)(a)].......................................... 2
2.3 Post -Construction Storm Water Management in New Development and Significant
Redevelopment [Permit Section I.B.(4)(d)].................................. 3
2.4 Flood Management Program [Permit Section I.B.(4)(d)] ... ...................... 6
2.5 Illicit Discharge and Improper Disposal Program [Permit Sections I.A.(4)(b), I.B.(3), and
I.B.(4)(a)].......................... ................................. 7
2.6 Industrial Runoff Program [Permit Section I.B.(4)(d)] ......................... 11
2.7 Construction Site Runoff Program [Permit Section 1.13.(4)(e)] .................. 13
2.8 Pollution Prevention/Good Housekeeping for Municipal Operations [Permit Sections
I.B.(4)(b) and I.B.(4)(d)] ................................................ 17
2.9 Monitoring Program [Permit Sections I.B.(1), I.B.(5), and I.B.(6)] ............... 21
2.10 Annual Report [Permit Section I.C.(3)]..................................... 22
2.11 Budget and Resources [Permit Section I.A(4)(e)] .............................. 23
APPENDIX A Summary of Public Education/Public Involvement Activities
APPENDIX B Industrial Sites
APPENDIX C Construction Sites
APPENDIX D Municipal Operations
September 28, 2006 1 Draft Report

Municipal Separate Storm Sewer System (MS4) Audit
Winston-Salem, North Carolina
• .Tune 27 - 29, 2006
INTRODUCTION
At the request of the U.S. Environmental Protection Agency (EPA) Region 4, a Municipal
Separate Storm Sewer System (MS4) Audit was conducted on June 27 - 29, 2006, at the City of
Winston-Salem, North Carolina. The audit team included Mr. Jerry Whittum and Ms. Carol
Winston of Science Applications International Corporation and Mr. Mike Randall, Mr. Ken
Schuster, and Mr. Bill Diuguid of the North Carolina Department of Environment and Natural
Resources (NCDENR).
The City of Winston-Salem (City) was issued National Pollutant Discharge Elimination System
(NPDES) Permit No. NCS000247, effective from November 1, 2001, to September 12, 2003
(2001 Permit). Winston-Salem received a draft permit for review in June 2006. The NCDENR
has not re -issued a permit to the City since that date. Winston-Salem is currently the single
permittee holder for the MS4 permit; there are no co-permittees, and none are anticipated. Under
the permit, the City is required to develop and implement a Stormwater Program. Per Section A
of NPDES Permit No. NCS000247, the City's Stormwater Program includes the applicable
components of the City's MS4 NPDES permit application and its Stormwater Quality
Management Plan (SQMP). The City submitted to the NCDENR Division of Water Quality its
Stormwater Management Program Report, Municipal NPDES Stormwater Permit Renewal
Application dated October 25, 2005 (2005 Stormwater Management Program Report). The MS4
audit team used the 2001 Permit and the 2005 Stormwater. Management Program Report to
evaluate the City's MS4 program.
The remainder of the report summarizes the findings of the MS4 audit organized by the
individual stormwater program components. Each section contains a summary of the findings
associated with each program component and required or recommended actions.
FINDINGS
2.1 General Findings
Under Part I.A of Permit No. NCS000247, the City's Stormwater Program includes applicable
components of the City's MS4 NPDES application and its Stormwater Quality Management Plan
(SWQMP). The City did not have a specific document titled the SWQMP, but indicated that its
stormwater program was described in its 2005 Stormwater Management Program Report, Some
BMPs listed in the 2005 Stormwater Program Management Report did not reflect the activity
currently being implemented by the City. These are discussed in the appropriate sections
throughout this report.
September 28, 2006 1 Draft Report

Recommended action: The City should update the 2005 Stormwater Management Program
Report to ensure that it contains an accurate and current list of the City's program
implementation activities. If the City has proposed changes to its stormwater program (as
described in its 200; Stormwater Management Program Report), the City must adequately
describe andjustify these proposed changes in its annual report in accordance with Section
I.C. (3)(b) of Permit No. NCS000247.
2.2 Public Education and Outreach Program/Public Involvement and Participation
[Permit Sections I.A.(4)(f) and I.11.(4)(a)]
The.MS4 audit team interviewed Ms. Roseann L'Esperance, Community Educator, regarding the
City's public education and outreach and public participation programs. The City implements an
extremely active public education and public involvement program, conducting many types of
education and involvement activities aimed at the various audiences in Winston-Salem. Of
particular note are the City's efforts in the following areas:
• Targeting its Hispanic community through various communication and outreach methods.
• Targeting Winston-Salem students through a wide variety of interactive and innovative
mechanisms and involvement opportunities.
• Using every possible community event to distribute. educational materials and
communicate with its residents.
In addition, the City has worked with various agencies (e.g., Piedmont Triad Water Quality
Partnership) to leverage its available resources and implement cost-effective activities. For
example, whenever possible, Ms. L'Esperance uses stormwater education materials developed by
other agencies.
An overview of the status of various activities conducted by the City is provided in Appendix A.
Findings associated with the review of these activities are as follows:
• BMP 16 (City of Winston-Salem University) is not implemented as described in the 2005
Stormwater Management Program Report. According to its description, the City will
provide training for all new employees. According to Ms. L-Esperance, this BMP
actually involves a training course to directly teach the public about municipal
government.
• BMP I I (Green Business Program) is not yet being implemented. The City is currently
working on the program concept.
Required actions: None.
Recommended actions: The City should move forward as quickly as possible to implement BMP
] ] (Green Business Program). (Also see recommended action for BMP 16 in Section 2.8.2 of
this report)
September 28, 2006 2 Draft .Report

2.3 Post -Construction Storm Water Management in New Development and Significant
Redevelopment [Permit Section I.B.(4)(d)J
The City currently has requirements for post -construction stormwater management for watershed
areas that are classified as Water Supply. These requirements are found in the specific watershed
regulations (i.e., Article III - Salem Lake Watershed Protection). The Salem Lake Watershed
Protection regulations provide three options for development: low density, stormwater quality
management, or special intense development.
Stormwater quality management requirements in the Water Supply watershed areas
The stormwater quality management option for land development is used when a proposed
development exceeds the low density option provisions. Per Section 3-5.3 of the Salem Lake
Watershed Protection regulations, under this option, a stormwater quality management permit is
required, and the development must meet the following requirements:
• All residential development must be done in accordance with the provisions of the
Zoning Ordinance.
The built -upon area of residential development must not exceed 30% of the site.
In approving site plans, the Planning Board must determine that the area with impervious
surface cover is designed and sited to minimize stormwater runoff and limit concentrated
stormwater flow; and that land disturbance is minimized, existing vegetated areas are
retained to the maximum degree possible, and all undeveloped areas will be revegetated
to promote stormwater infiltration.
In obtaining the stormwater quality management permit, the applicant must provide the plans and
specifications for the stormwater control structure. The City allows wet detention ponds or
alternative stormwater systems approved by the State. Wet detention ponds must be designed as
follows:
• designed to remove 85% total suspended solids (TSS) in the permanent pool and storage
runoff from a one -inch rainfall from the site above the permanent pool;
• designed storage volume is above the permanent pool;
• discharge rate must be such that the runoff does not draw down to the permanent pool
level in less than two days and that the pond is drawn down to the permanent pool level
within at least five days;
• mean permanent pool depth must be a minimum of three feet;
• inlet structure must be designed to minimize turbulence using baffles or other appropriate
design features; and
• vegetative filters must be constructed for the overflow and discharges and must be at least
30 feet in length.
Stormwater quality management requirements outside the Water Supply watershed area.,;
The City plans to adopt an ordinance to address post -construction stormwater management
controls in the other watersheds (i.e., outside the Watershed Protection areas) within the City's
jurisdiction. Proposed requirements were included in the 2005 Stormwater Management
September 28, 2006 3 Draft Report

Program Report. These requirements had two options for low density and high density projects
which include, but are not limited to the following:
• Low density projects must have no more than two dwelling units per acre or 24 percent
built -upon area and stormwater runoff must be transported from the development by
vegetated conveyances to the maximum extent practicable.
• High density projects (i.e., those projects which exceed the low density threshold) must
implement stormwater control measures that control and treat the difference in
stormwater runoff leaving the project site between the pre- and post -development
conditions for the one-year 24-hour storm. In addition, all structural stormwater controls
must be designed to have an average 85% TSS removal.
In Table 7.5.8 of the 2005 Stormwater Management Program, the City indicated that this
ordinance would be developed in Years I and 2. City staff noted that they are currently working
with their stakeholders to develop this program and then plan to take the ordinance to the City
Council for adoption. However, the City is waiting for the State to develop its program for post -
construction controls in Class C watersheds.
Development Plan Review Process
Applications are first submitted as a sketch plan if the plan is going through the Planning Board.
The plan undergoes an inter -departmental review (e.g., review by Stormwater and Utilities
Divisions) and then it goes through the Planning Board. The Planning Department is responsible
for compiling all City comments. The City has a completeness checklist to ensure that all
required items have been submitted. When the plan goes to the Planning Department, it will be
approved as is, approved with conditions, or not approved.
After approval of the subdivision plans, the applicant starts submitting construction drawings.
The Engineering and Stormwater Divisions each get a set of drawings to review. Checklists are
used by the reviewers to ensure that the applicant has submitted the required items.
Construction plans are reviewed by a Technical Review Committee (TRC) with representatives
from the City's Engineering, Stormwater, Erosion Control, Fire, and Utilities Divisions. In
addition the North Carolina Department of Transportation will participate when a State road is
involved, and the City Department of Transportation will participate when it is a City street.
Mr. Joe Fogarty, Development Plan Review, Stormwater Division, reviews the stormwater plans
and sends his comments (e.g., conditions for approval if appropriate). Likewise, the Erosion
Control staff in the Inspections Division will review the plans and submit any comments they
have (see related discussion in Section 2.7 of this report). Mr. Alston, City Engineering
Division, coordinates the reviewer's comments on the construction drawings and ensures
approval from the Stormwater Division staff.
City staff provided the MS4 audit team with a copy of a draft document titled Winston-Salem
Infrastructure Development Standards. This document contains detailed graphics illustrating the
September 28, 2006 4 Draft Report

City's typical development review process and platting process, a site plan submittal checklist,
and a section which describes the quantity control guidelines for stormwater. As described in the
document, a developer may have the requirement for a detention or retention structure waived if
stormwater from the proposed development discharges into an adequate drainage system or a
stormwater management study prepared by a Professional Engineer in the state of North Carolina
indicates that the proposed development will not have an adverse effect on the downstream
runoff rates for the 10- and 50-year storm events. If the requirement for a detention or retention
structure is not waived, the developer must construct a detention or retention structure to control
runoff. The Winston-Salem Infrastructure Development Standards contains the requirements for
the detention or retention structure.
Operation and Maintenance of Post -Construction Stormwater Controls
The City has an inventory of its post -construction controls as well as a list of post -construction
controls that are approved but not yet built. The list contains about 200 stormwater controls
including about 120 dry ponds, 35 to 40 oversized piping manifolds, and 35 to 40 wet ponds. The
City annually inspects these post -construction controls and documents any deficiencies.on an
inspection form. If there are deficiencies, the City notifies the owner. None of the post -
construction stormwater controls had major deficiencies, only minor issues such as debris build-
ups.
The City has not taken any enforcement actions for situations where there are deficiencies in the
operation and maintenance of the post -construction stormwater controls, but they currently have
one situation in the Water Supply Watershed where they may pursue an enforcement action.
In accordance with Section 3-6.3 of the Salem Lake Watershed Protection regulations, an
applicant must provide adequate financial assurance in the form of a performance bond and/or
other cash security, together with a contractual lien upon the property for the purpose of assuring
construction, continued maintenance, repairs or reconstruction if necessary for adequate
completion and continued maintenance of any stormwater control structures. The applicant must
also sign an operation and maintenance agreement for the stormwater control structure.
Fecal Col form Source Control
Section 7.5.3 of the 2005 Stormwater Management Program indicates the City will (1) work with
the Forsyth County Health Department to include an oversight program to ensure proper
operation and maintenance of on -site wastewater treatment systems and (2) implement BMPs
that encourage the die -off offecal coliform bacteria to the maximum extent practicable. BMP 4
(Fecal Coliform Control) in Section 7.5.8 of the 2005 Stormwater Management Program Report
states that the City will develop a procedure with the County health department to ensure proper
septic operations.
For this BMP, the City stated that as part of their special projects (e.g., stream restoration and
design), they have been piloting BMPs that have typically performed well on reducing fecal
coliform levels. The City has also been working as part of the City -County Utilities Commission
September 28, 2006 5 Draft Report

to identify failing sections of the sanitary sewer collection system through field and Sanitary
Sewer Overflow (SSO) monitoring. The City did not discuss any procedures or an oversight
program with the County health department to ensure proper septic operations.
Post -Construction Education
In Table 7.5.8 of the 2005 Stormwater Management Program, the City indicated that it will
provide education to the development and design community on new regulations and how to
comply. The City indicated they are working with North Carolina State University and the
Cooperative Extension Service to combine resources and conduct training seminars.
Required actions: None.
Recommended actions: The City should:
(I) ensure that they move forward as soon as possible to enact an ordinance addressing post -
construction controls for areas outside the Water Supply Watershed.
(2) implement BMP 4 (Fecal Coliform he
as described in the 2005 Stormwater
Management Program Report or revise as appropriate. In addition, if the BMP is changed, the
proposed change must be adequately described and justified in the City's annual report in
accordance with Section 1. C. (3) (b) of Permit No. NCS000247.
2.4 Flood Management Program [Permit Section LB.(4)(d)]
In its 2005 Stormwater Management Program, the City noted that it has a local Flood Plain
Management Program that coordinates with the Federal Emergency Management Agency
(FEMA) and the National Flood Insurance Program (NF1P). Chapter C of Article II of the City's
Unified Development Ordinance contains Floodway and Floodway Fringe Regulations.
The City provided a summary of its Watershed Master Plans dated August 6, 2003 (Watershed
Master Plan Summary) to the MS4 audit team. One objective of the Watershed Master Plans
was to identify areas of existing and potential flooding and potential solutions. After the City
identified all the problems, potential projects were identified and assigned to one of the following
funding categories:
• Identified with correction on a State -maintained road
• Added to current maintenance list for repair
• Candidates for the current policy for participation on private property (60/40 program)
• Projects that will become a maintenance project when conditions warrant
• Projects for which currently there is no policy to correct
• Projects that need to be added to the City's capital improvement program
• Projects already completed by the City or other agency.
The majority of proposed flood management projects with water quality features (designated as
bioremediation in the Watershed Master Plan Summary) are categorized as candidates for the
current policy for participation on private property (60/40). The City indicated that these
September 28, 2006 6 Draft Report

projects, listed as bioremediation in the Watershed Master Plans, are funded via the City's 60/40
Public/Private Partnership Policy. Under this policy, the City will repair and restore the stream
and pay 60% of the costs if the homeowner agrees to pay 40% of the costs. Currently, the City is
working on two or three projects under this policy; they average about four to five such projects
per year. City staff noted that these projects can be cost -prohibitive to a homeowner. In
addition, very few homeowners even know that a project for their property has been identified in
the Watershed Master Plan as having a potential bioremediation/stream enhancement project.
The City looks to see where these bioremediation projects can be'integrated with other projects
that the City is implementing. City staff also noted that they have two manuals related to stream
management and restoration - one for developers and commercial -projects and one for individual
homeowners.
Some other projects which could potentially include water quality features are listed in the
funding category for which there is currently no policy to correct. For example, three upstream
detention projects in the Brushy Fork Watershed are listed in this funding category.
The City used the Watershed Master Plans to develop the stormwater Capital Improvement
Projects for 2006-2007. This list included five projects estimated to cost approximately
$876,000. The projects were primarily pipe and culvert replacements. .
Required actions: None.
Recommended actions: The City should:
(1) implement procedures to note homeowners about their properties being included as
potential bioremediation projects in the. Watershed Master Plans and encourage these
homeowners to participate in the 60140 Public/Private Partnership Program. .
(2) review all potential flood management projects to determine whether it is feasible to include
water quality features.
2.5 Illicit Discharge and Improper Disposal Program [Permit Sections LA.(4)(b), I.B.(3),
and I.13.(4)(a)]
2.5.1 Storm Sewer System Map
The City has mapped and included in a Geographic Information System (GIS) the City streets,
topography, drainage basins and subbasins, aerial maps, watersheds down to one acre, large
lakes, and industrial addresses. The mapping includes all storm sewers, inlets, catch basins, and
outfalls located in the public right-of-way. The mapping does not include storm sewers that are
not in the public right-of-way (i.e., on private property). The private property storm sewers may
be connected to the City MS4 and therefore receive and convey flow from the MS4 to an outfall
to receiving waters. The City mapping does not include all MS4 flow outfall locations. The City
mapping does not include either the stormwater management facilities (i.e., bioretention cell,
constructed wetlands, created floodplain) or municipal operations (e.g., Streets Division). BMP
September 28, 2006 7 Draft Report

15 (Stormwater Sewer Inventory) in Sections 7.3.1 and 7.3.2 of the 2005 Stormwater
Management Program Report identifies mapping as a means to fulfill the permit requirement to
detect and eliminate illicit discharges.
Required actions: None.
Recommended actions: The City should add to its mapping and GIS (1) all private property
storm sewers that convey and/or discharge MS4 flows and (2) locations of stormwater
management facilities/BMPs and municipal operations.
2.5.2 Legal Authority/Regulatory Mechanism and Enforcement
The City's legal authority to prohibit illicit discharges is found Section 75-6 of the Stormwater
Management Ordinance, which states that "it is unlawful for any person to allow, directly or
indirectly, anything other than stormwater, whether solid, liquid or vegetative, to be discharged,
deposited or placed in such location that it may reach or be blown or scattered into the MS4..."
Required actions: None.
Recommended actions: None.
2.5.3 Dry Weather Screening
Permit Section 1.B.(3) requires the City to locate and identify additional sources of stormwater
discharge not previously identified in the permit application process or previous permit terms.
This includes the location and characterization of major outfalls from the MS4 and any activities
or facilities discharging to the MS4 that were not previously located but are expected to
contribute pollutants to the MS4. The City has reportedly identified all major and minor outfalls
located in the public right-of-way. The City has not identified and does not monitor or observe
the private property outfalls that receive contributing flows from the MS4. Thus, the private
property outfalls are not screened for dry weather flows that may originate in the MS4.
Required actions: None.
Recommended actions: The City should ensure that private property outfalls that receive flow
from the MS4 are included in the dry weather screening program.
2.5.4 Activities to Detect Illicit Discharges/ Follow -Up Investigation
BMP 3 (Infrared Photography), BMP 7 (Stream Walking), and BMP 9 (Visual Observations) in
Section 7.3.1 of the 2005 Stormwater Management Program Report identify means to assist in
detection of illicit discharges. The City conducted a one-time infrared photography study on
March 4, 2003. City staff continue to walk the stream main stems to visually inspect for dry
September 28, 2006 8 Draft Report

weather discharges and anticipate this initial visual inspection of the stream main stems will be
completed within three years. The City also identifies dry weather discharges through the
industrial pretreatment program, monitoring, citizen complaints, and random sightings by City
employees during normal duties. The City does not observe and/or monitor the private property
storm sewer outfalls that receive and convey MS4 flow. Thus, the private property outfalls are
not visually observed for illicit discharges that originate in the MS4.
The City does not have an ongoing, mandatory program to train newly -hired pertinent City staff
(e.g., streets maintenance and sanitation staff) to observe for illicit discharges during work -
related travel in the City.
Required actions: None.
Recommended actions: The City should:
(1) ensure that the private property outfalls that receive flow from the MS4 are visually observed
to detect illicit discharges.
(2) implement an illicit discharge training program for newly -hired pertinent City employees
that have job duties that require routine travel throughout the City (e.g., street maintenance'and
sanitation).
2.5.5 Spill; Response Program
The Stormwater Division staff can respond to low level (i.e., residential size quantities) spills.
The Fire Department receives the 911 telephone calls for reported spills. The Fire Department
and/or Fire Department Hazardous Material teams are typically the first responders for spills.
The City/County Emergency Management staff also respond when notified. The Fire
Department vehicles contain absorbent, booms, and dams. The first responders contain, apply
absorbent, and ensure the cleanup of minor spilled material and absorbent. The Emergency
Management staff ensure the cleanup of major spills. The Fire Department and Hazardous
Material staff do not notify the Stormwater Division when responding to a spill that could or
does enter the MS4.
The Fire Department, as first responders to spills, is likely using an old and incomplete map of
the storm sewer system for determining the flow path of spills into the MS4.
Required actions: None.
Recommended actions: The City should:
(1) ensure that the Fire Department and Stormwater Division develop a mechanism whereby the
Fire Department will notify the Stormwater Division of any spill that may, has, or is entering the
MS4. The Stormwater Division management can then determine the need to send staff to the
spill site.
(2) provide the Fire Department with a current map of the MS4.
September 28, 2006 9 Draft Report

2.5.6 Promote Public Reporting of Illicit Discharges and Improper Disposal
The City operates a stormwater hotline to report pollution problems including illicit discharges
and illegal dumping. The stormwater hotline operator notifies the Stormwater Division or Public
Works Department staff.
The City operates a Citizen Request Management system (CRM) that is available on the City's
website and ensures response to all queries from citizens. The CRM system provides a means for
the public to report illicit discharges. The public is educated about water quality protection
through program components such as storm drain stenciling, door hangers, and brochures.
Required actions: None.
Recommended actions: None.
2.5.7 Household Hazardous Wastes and Used Motor Oil
The City provides free disposal of household hazardous waste (HHW) and used motor oil at a
City -funded facility that is operated by Resource, Recovery, and Reduction Company (3RC), a
private company. The 3RC operates a drop-off site from 9:00 A.M. to 2:00 P.M. Tuesday
through Friday and from 9:00 A.M. to 12:00 Noon on Saturday. The 3RC accepts HHW such as
paint, strippers, thinners, solvents, pesticides, household cleaners, batteries, gasoline, antifreeze,
and used oil. The 3RC location and services information are provided on the City website. The
City tracks the gallons of used oil collected annually.
Required actions: None.
Recommended actions: None.
2.5.8 Control of Sanitary Seepage into the MS4
The City Public Works Department operates an SSO control program as part of the ongoing
Capacity, Management, Operation and Maintenance program for the sanitary sewer. SSO
locations are included in the City GIS mapping. The Public Works Department notifies the
Stormwater Division of all SSOs that are 1,000 gallons or greater. City staff noted that no cross
connections between the sanitary and storm sewers have been found. The City sanitary and
storm sewers are not buried in a common trench.
Required actions: None.
Recommended actions: The Public Works Department should immediately notify the
Stormwater Division of all SSOs that discharge to the MS4.
September 28, 2006 10 Draft Report

2.6 Industrial Runoff Program tPermit Section I.B.(4)(d)J
Regulatory Mechanism
The City's legal authority for the industrial control program is found in Chapter 75 - Stormwater
Management Ordinance, Article I. Illicit Stormwater Discharges and Connections. Under
Section 75-8, the Stormwater Manager or his designee is given the right to inspect, sample, and
examine all discharges at the industrial facilities and to install or require the industrial facility to
install devices to monitor and sample the facility's discharges. Under Section 75-9, the
Stormwater Manager or his designee has the authority to require BMPs for any facility which
may cause or contribute to an illicit discharge to the MS4. Section 75-1 1 contains the
enforcement authority for violation of this ordinance which includes but is not limited to the
issuance of Notices of Violation (NOVs) and civil penalties.
Facility Inventory
The industrial inventory provided to the MS4 audit team was not the most recent version. The
inventory consists of facilities that filed Notices of Intent (NOIs) for.coverage under the State
industrial general permit (State general permit). Initially, the City started with a comprehensive
list from the State Basin Inventory Management System (BIMS). In reviewing the information
on industries in the City, City staff review permit dates, expiration dates, and rescinded permits.
City staff review BIMS information monthly.
In addition, if the City finds a facility with an illicit discharge, they determine whether the facility
is covered under the State general permit and if not, whether the facility should be covered. If
the facility should be covered under the State general permit but is not, the City inspector tells the
facility to call the State, and the City will also call the State. The City provides the State with a
copy of the illicit discharge investigation.
Best Management Practices Education
BMP 13 (BMP Education with Commercial Facilities) in Section 7.3.1 of the 2005 Stormwater
Management Report indicates that the City will assess commercial facilities for actual or
potential sources of pollutants and show them alternative practices, including structural and non-
structural BMPs. City staff indicated that this is done as part of the inspections of NPDE-S-
permitted facilities. The City distributes to these facilities a brochure developed specifically for
businesses titled Stormwater Runoff What Your Business Needs to Know as well as a poster titled
Storm Water Pollution Prevention. Other commercial facilities, which are not on the City's list
of facilities to be inspected, are not being assessed or provided with educational/outreach
materials under this BMP.
Inspections
The City's process for conducting industrial inspections is to thoroughly review all paperwork
(e.g., SWPPP and self -inspection reports, economic feasibility) and conduct a site work -through.
The City provided to the MS4 audit team a copy of its Surface Water Inspection for Industrial
Sites form. The inspection form covers all paperwork and records that the facility is required to
September 28, 2006 11 Draft Report

maintain under the State general permit. The form also has a section titled Facility Tour:
Comments and Observations where the City inspector provides recommendations or corrective
actions for the facility.
Using this inspection approach, the City has been able to inspect approximately 29 of its
approximately 70 industries in the past few years. Under BMP I(Industrial Inspections) in
Section 7.3.1 of the 2005 Stormwater Management Report, the City will conduct 12 industrial
inspections per year. At this rate, it will take the City several more years to complete its initial
inspections of these facilities.
During the audit, the MS4 audit team observed City inspectors conducting inspections of the
Hanes and Salem trucking industrial facilities. Detailed summaries of these site visits are
included in Appendix B. General findings include:
The City inspectors conducted a very thorough and comprehensive inspection at the
Hanes facility. During the site inspection, City inspectors used the site plan to conduct
the inspection ensuring that the plan accurately reflected the on -site activities (e.g.,
materials storage, unloading, oil storage containers).
The inspectors handled an unannounced inspection at Salem Carriers very well. The
MS4 audit team requested that an inspection be conducted at this transportation facility
without advance notification. The City inspectors provided an explanation of the
inspection process and the purpose of the inspection such that the Salem Carriers facility
and corporate staff were comfortable in allowing the inspection to proceed.
Enforcement
Following an inspection, the City inspectors typically send a letter with the completed inspection
report to the inspected industry. There has not been follow-up on several industries that have
been inspected since 2004. Typically the City will include corrective actions to be taken by the
facility in the completed inspection report (as mentioned above) and the follow-up letter. The
City does not always include a deadline by which these corrective actions must be taken but
rather requests notification to the Stormwater Division when the facility has completed such
corrective actions. The City will then schedule a re -inspection to verify that the actions were
taken, depending on staff availability.
The City provided the MS4 audit team with a document titled "Unresolved Issues from Industrial
Surface Water Inspections." Seven of the ten industries in this document were originally
inspected in 2004 and two were inspected in January and February of 2005. While many of the
corrective actions to be taken involved paperwork (e.g., incorporate delineation lines onto the site
map in the SWPPP, certification statement regarding non-stormwater discharges, reporting
procedures for spills, etc.), some corrective actions, if not completed in a timely fashion, could
have a significant impact on stormwater discharges from the facility. For example, one
corrective action for Royster Clark included addressing spent wooden pallets with waste fertilizer
September 28, 2006 12 Draft Report

(dumpster is open and not water -tight) and similarly, a corrective action for Lyndon Steel
involved covering existing waste scrap metal dumpsters or obtaining water -tight dumpsters to
eliminate metal fines from entering the environment.
The City does not have a written enforcement response plan or procedures for its industrial
runoff program.
Required actions: None.
Recommended actions: The City should:
0) ensure that its list of industrial facilities is kept up-to-date.
(2) because of the limited time available for industrial inspections, revise its inspection process
by prioritizing the facilities for inspection and conducting streamlined inspections that focus on
areas that could have impact on stormwater quality (e.g., outside uncovered containers with
waste materials, potential connections of a drain inside the facility to the storm sewer system,
outside loading/unloading and raw material or trans r areas). In this way, the City inspectors
could potentially inspect more industrial facilities annually.
(3) evaluate and ensure that the industrial runoff program component has adequate funding crud
staff resources for program implementation.
(4) consider including timeframes (i.e., compliance schedules) far taking corrective action by
industrial facilities and conducting the follow-up inspections in a reasonable timeframe to verb
compliance.
(5) develop enforcement procedures or an enforcement response plan which describes different
types of deficiencies (e.g., discharges of pollutants in stormwater runoff from loading/unloading
areas, spilled petroleum products in area outside the vehicle maintenance shop) and escalated
enforcement actions based on the types of violation and continuing noncompliance.
2.7 Construction Site Runoff Program [Permit Section I.B.(4)(e))
Regulatory Mechanism
The City's authority for its construction sites runoff program is found in Chapter C -
Environmental Ordinance, Article V1I - Erosion Control. In accordance with Section 7-5.1 of
Article III, no person may initiate any land disturbing activity without first obtaining a permit and
obtaining an erosion control plan approved by the Director of Inspections. Specific items that
must be included in the erosion control plan are detailed in Article VII. In addition, the
following are required:
• Erosion and sedimentation control measures, structures, and devices must be planned,
designed, and constructed to provide protection from the calculated maximum peak
runoff from the ten-year storm (Section 7-8.1).
• In high quality water zones, erosion and sedimentation control measures, structures, and
devices must be planned, designed, and constructed to provide protection from the runoff
of the 25-year storm [Section 7-8.2(B)].
September 28, 2006 13 Draft Report

• Sediment, open channels, and ground cover have specific design and construction
requirements [in Sections 7-8.2(C), (D), and (E) respectively].
City staff noted that their erosion control requirements are based on the State handbook, which
has been adopted by the City.
Enforcement authority in the Article allows for issuance of NOVs, civil penalties of not more
than $5,000, criminal penalties, which include a fine not to exceed $5,000, and injunctive relief.
Plan Reviews
Plan reviews are performed by the City's three erosion control inspectors: Mr. Tommie Beeding,
Mr. Fred Bowen, and Mr. David Evans. These inspectors are located within the Inspections
Division and are supervised by Mr. Jeff Kopf, Erosion Control Engineer/Floodplain Manager:'
The inspectors are assigned to specific areas of the City and perform the plan reviews and
inspections for those areas. - Sometimes the geographic areas overlap, and the City attempts to
balance the number of projects assigned to the inspectors. Plan reviews are initially completed
by the inspector; then a joint review is done in which the supervisor reviews all plans with the
responsible inspector.
The inspectors provided copies of the following three documents to the MS4 audit team:
(1) Erosion and Sedimentation Control Plan Checklist: - This checklist includes sections for
review of general site features; site drainage features; erosion control measures (including
location of temporary and permanent measures; construction drawings and details for temporary
and permanent measures; design calculations for a sediment basin and measures; maintenance
requirements and person responsible for maintenance); vegetative stabilization; and other
requirements (e.g., construction sequence, nature and purpose of construction).
(2) List of notes that address construction sequence and erosion control maintenance activities to
be included in erosion control plans.
(3) Internal Erosion Control Plan Review Check -Off List: The inspectors use this list to ensure
that all required items and activities have been completed for Erosion Control Plan approval.
This check -off list includes a note that the NPDES General Permit for stormwater discharges
associated with construction activities has been attached to the approved Erosion Control Plan
and provided to the project applicant.
The City forwards all copies of issued Erosion Control Permits to the State.
In Spring 2006, the City implemented a Residential Erosion and Sediment Control Program for
all residential single family homebuilders. The City has one inspector, Mr. Russell Yoder, who
is responsible for inspections of individual single family residences. The program is designed to
maintain a positive relationship between homebuilders and the inspections Division. Mr. Yoder
provided a copy of an excellent educational package provided to single family homebuilders
which provides sections of the Erosion Control Ordinance, information on various erosion
control measures (with photographs), and a description of the inspection process and what
happens in the event of noncompliance. He also provides the homebuilders with a brochure
September 28, 2006 14 Draft Report

titled Controlling Sediment on Single -Family Dwelling Construction Sites which contains
information and graphical representations of silt fence, trackout pads, energy dissipators, and
natural buffers.
Site Inspections
City staff indicated that they conduct approximately 1,900 inspections of both City and County
construction sites per year; Mr. Kopf subsequently indicated that from July 1, 2005 through June
28, 2006, 1,292 construction site inspections were conducted within the City. Sites are
prioritized for inspection based on several factors including the complexity and size of the site.
Usually, sites are inspected once every four to five weeks. Sites will sometimes be inspected
after wet weather events, but primarily in response to complaints.
City inspectors provided a copy of the Sedimentation Inspection Report form which they use for
inspections.
Results from the MS4 audit team's review of the construction files were as follows:
General Findings: The City inspectors are maintaining all records and documentation
associated with a construction site. However, in some cases, the three City inspectors are
not completing their forms in the same way. Copies of issued permits in the files did not
have the dates of issuance, and financial responsibility forms had incomplete contractor
information.
Legacy Park File Review: Inspections conducted on May 1st, May 15th and June 26th
show corrective actions that need to be taken. The checklist questions which indicate
type of violations (No. 5 in checklist) were not completed in the May Ist and May 15th
inspection reports. Following the June 26th inspection, the City issued an NOV to the
Legacy Park site indicating that failure to undertake the corrective actions specified in the
NOV by July 14th could result in a suit for injunction and assessment of a civil penalty.
Spencer Memorial Church File Review: Numerous inspections were conducted during
the timeframe of September 30, 2005 through May 23, 2006. Many inspection reports
showed the site to be out of compliance and to need corrective actions. Although the City
issued an NOV and demanded payment of a civil penalty in the amount of $1,800 on
October 4, 2005, the site still had noncompliance issues as documented in inspections
conducted on October 31, 2005, November 2, 2005, March .l7, 2006, April 11, 2006, and
April 25, 2006. A second NOV was issued on May 23, 2006; however, the site continues
to have noncompliance issues (see description below of MS4 audit team site visit) and
Appendix C.
During the audit, the MS4 audit team observed City inspectors conduct inspections of the Legacy
Park and Spencer Memorial Church construction sites. Detailed summaries of these site visits
are included in Appendix C. General findings include:
September 28, 2006 15 Draft Report

The City inspectors typically did not have adequate time to conduct a thorough
inspection. One inspector is currently assigned 98 construction sites along with other
duties, such as plan review, as described previously. Thus, the inspector cannot conduct
thorough site inspections as often and at the level of detail needed.
Stormwater BMPs were not being installed per the approved erosion control plans. For
example, at the Legacy Park site, a large portion of the site was sloped to direct
stormwater around the detention pond to a low area that was overloaded with sediment,
and the low area was not designed per the erosion control plan. At the Spencer Memorial
Church site, an additional'outfall on the erosion control plan had not been installed, and
the City inspector was not aware of this.
The City inspectors are trained through the State land quality workshops.
Enforcement
City staff described their enforcement actions. If there is off -site sedimentation to a watercourse,
the City immediately issues a civil penalty with a minimum of $1,000 and a higher penalty based
on the acreage disturbed (generally $100 per acre disturbed). If the site had an approved erosion
control plan, but didn't install erosion control measures, a penalty of $1,000 minimum plus $100
per disturbed acre would be assessed. If the site was in noncompliance with the erosion control
plan, a noncompliance report would be issued and the site would be given a deadline to correct
the noncompliance (one or two weeks depending. on the potential for off -site sedimentation). If
the corrective actions have not been taken by the deadline, the City will issue an NOV. The
NOV will give a second deadline to implement corrective actions. If the corrective actions have
still not been taken by that second deadline, the City will issue a civil penalty which is retroactive
to the date of the NOV. The City does not have a written enforcement plan or procedures which
describe the enforcement process and procedures for escalating enforcement.
The City has issued NOVs to about 25 and 15 separate sites in 2005 and 2006 (through June)
respectively. The City also collected several penalties in 2005 and 2006. The City has repeat
and continuing noncompliance problems at the same construction sites.
Training and Education for Construction Site Operators
The City does not have a formal program for providing outreach and training for construction site
operators. The most recent presentation or workshop was several years ago, but they are
considering conducting a workshop in Fall 2006.
Required actions: None.
Recommended actions: The City should:
(1) review how City inspectors are completingforms and develop guidelines so that the forms
are completed consistently.
September 28, 2006 16 Draft Report

NC®ENR
North Carolina Department of Environment and
Beverly Eaves Perdue
Governor
Tom Griffin
Winston-Salem MS4
101 N Mail St
Winston-Salem, NC 27102
SUBJECT: Delinquent Annual Fees
Permit Number NCS000247
Winston-Salem MS4
Forsyth County
Dear Mr. Griffin:
Division of Water Quality
Coleen H. Sullins
Director
August 16, 2010
RECEIVED
N.C. 0eot.
AUG 19 F2010
winstorT-Sale;
Regionai Offce
Natural Resources
Dee Freeman
Secretary
All NPDES permittees must pay an Annual Compliance Monitoring Fee, This requirement is documented in
your current permit in Part V ('nor, in the case of Mining Activities, Part VI), As of the date of this letter, fees
for your facility have not been paid. The total amount presently owed is $3,440.00. Please return your
payment to the address listed below by September 16, 2010.
In addition, please be advised that failure to pay the annual fee is grounds for revocation of your permit, as
documented at 15A NCAC 2H.0105 (b)(4). This letter serves as notice that the Division will refer uncollected
fees to the North Carolina Attorney General's Office for collection through the courts unless payment in the
amount of $3,440.00 is received by September 16, 2010. Further enforcement action [ including the
revocation of the permit, imposition of civil penalties, and notification of the county health department] may
also occur if the fees remain unpaid.
Make checks payable to NC DENR, include the permit number on the check, and send the fee payment to:
Fran McPherson
Annual Administering & Compliance Fee Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
If you have questions regarding this matter, contact me at [phone] or Niki Maher at [phone].
Sincerely,
John Hennessy
Nonpoint Source Assistance & Compliance
Oversight Unit Supervisor
cc: DWQ Central Files
DWQ Winston-Salem Regional Office- Surface Water Protection Secti
��f:)
DWO NPSACOU file
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One 1,
512 North Salisbury Street, Raleigh, North Carolina 27604 1� ortl lCarolina
Phone: [phone] FAX [phone] /www.ncwaterquality.org ;Vaturally
An Equal Opportunily/Affirmative Action Employer - 50% Recycled110% Post Consumer Paper

Application requirements from 40 CFR 122 for large and medium municipal separate storm sewer
discharges.
Regarding inventory (or mapping) outfalls (that may discharge through Private Property).
The permittee must identify.... "The location of any major outfall that discharges to waters of the
United States. Provide an inventory, organized by watershed of the name and address, and a
description (such as SIC codes) which best reflects the principal products or services
provided by each facility which may discharge, to the municipal separate storm sewer, storm
water associated with industrial activity."
Major municipal separate storm sewer outfall (or "major outfall") means a
municipal separate storm sewer outfall that discharges from a single pipe with an
inside diameter of 36 inches or more or its equivalent (discharge from a single
conveyance other than circular pipe which is associated with a drainage area of
more than 50 acres); or for municipal separate storm sewers that receive storm
water from lands zoned for industrial activity (based on comprehensive zoning
plans or the equivalent), an outfall that discharges from a single pipe with an
inside diameter of 12 inches or more or from its equivalent (discharge from other
than a circular pipe associated with a drainage area of 2 acres or more).
Outfall means a point source as defined by 40 CFR 122.2 at the point where a
municipal separate storm sewer discharges to waters of the United States and
does not include open conveyances connecting two municipal separate storm
sewers, or pipes, tunnels or other conveyances which connect segments of the
same stream or other waters of the United States and are used to convey waters
of the United States.
Regarding inspections of industrial activies....
The permittee must provide...."A description of a program to monitor and control pollutants in storm
water discharges to municipal systems from municipal landfills, hazardous waste treatment,
disposal and recovery facilities, industrial facilities that are subject to section 313 of title III of
the Superfund Amendments and Reauthorization Act of 1986 (SARA), and industrial facilities
that the municipal permit applicant determines are contributing a substantial pollutant loading
to the municipal storm sewer system. The program shall: Identify priorities and procedures for
inspections and establishing and implementing control measures for such discharges; Describe a
monitoring program for storm water discharges associated with the industrial facilities, to be
implemented during the term of the permit, including the submission of quantitative data on the
following constituents: any pollutants limited in effluent guidelines subcategories, where applicable;
any pollutant listed in an existing NPDES permit for a facility; oil and grease, COD, pH, BOD5, TSS,
total phosphorus, total Kjeldahl nitrogen, nitrate plus nitrite nitrogen, and any information on
discharges required under Sec. 122.21(g)(7) (vi) and (vii)."
Regarding pesticides.......
The permittee must provide...."A description of a program to reduce to the maximum extent
practicable, pollutants in discharges from municipal separate storm sewers associated with the
application of pesticides, herbicides and fertilizer which will include, as appropriate, controls such as
educational activities, permits, certifications and other measures for commercial applicators and
distributors, and controls for application in public right-of-ways and at municipal facilities."

40 CFR 122
TITLE 40--PROTECTION OF ENVIRONMENT
PART 122--EPA ADMINISTERED PERMIT PROGRAMS: THE NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM
Subpart A --Definitions and General Program Requirements
Sec. 122.1 Purpose and scope.
Sec.122.2 Definitions
Municipality means a city, town, borough, county, parish, district, association, or other public body created
by or under State law and having jurisdiction over disposal of sewage, industrial wastes, or other wastes,
or an Indian tribe or an authorized Indian tribal organization, or a designated and approved management
agency under section 208 of CWA.
Point source means any discernible, confined, and discrete conveyance, including but not limited to, any
pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal
feeding operation, landfill leachate collection system, vessel or other floating craft from which pollutants
are or may be discharged. This term does not include return flows from irrigated agriculture or agricultural
storm water runoff. (See Sec. 122.3).
Schedule of compliance means a schedule of remedial measures included in a "permit", including an
enforceable sequence of interim requirements (for example, actions, operations, or milestone events)
leading to compliance with the CWA and regulations.
Subpart B--Permit Application and Special NPDES Program Requirements
Sec. 122.26 Storm water discharges (applicable to State NPDES programs, see Sec. 123.25).
(a) Permit requirement.
(3) Large and medium municipal separate storm sewer systems.
(i) Permits must be obtained for all discharges from large and medium municipal separate storm
sewer systems.
(ii) The Director may either issue one system -wide permit covering all discharges from municipal
separate storm sewers within a large or medium municipal storm sewer system or issue
distinct permits for appropriate categories of discharges within a large or medium municipal
separate storm sewer system including, but not limited to: all discharges owned or operated
by the same municipality; located within the same jurisdiction; all discharges within a system
that discharge to the same watershed; discharges within a system that are similar -in nature',
or for individual discharges from municipal separate storm sewers within the system.
(iii) The operator of a discharge from a municipal separate storm sewer which is part of a large or
medium municipal separate storm sewer system must either:.
(A) Participate in a permit application (to be a permittee or a co-permittee) with one or more
other operators of discharges from the large or medium municipal storm sewer system
which covers all, or a portion of all, discharges from the municipal separate storm sewer
system;
(B) Submit a distinct permit application which only covers discharges from the municipal
separate storm sewers for which the operator is responsible; or
(C) A regional authority may be responsible for submitting a permit application under the
following guidelines:
(1) The regional authority together with co -applicants shall have authority over a storm
water management program that is in existence, or shall be in existence at the time
part 1 of the application is due;

40 CFR 122
(2) The permit applicant or co -applicants shall establish their ability to make a timely
submission of part 1 and part 2 of the municipal application;
(3) Each of the operators of municipal .separate storm sewers within the systems
described in paragraphs (b)(4) (i), (ii), and (iii) or (b)(7) (i), (ii), and (iii) of this section,
that are under the purview of the designated regional authority, shall comply with the
application requirements of paragraph (d) of this section.
(iv) One permit application may be submitted for all or a portion of all municipal separate storm
sewers within adjacent or interconnected large or medium municipal separate storm sewer
systems. The Director may issue one system -wide permit covering all, or a portion of all
municipal separate storm sewers in adjacent or interconnected large or medium municipal
separate storm sewer systems.
(v) Permits for all or a portion of all discharges from large or medium municipal separate storm
sewer systems that are issued on a system -wide, jurisdiction -wide, watershed or other basis
may specify different conditions relating to different discharges covered by the permit,
including different management programs for different drainage areas which contribute storm
water to the system.
(vi) Co-permittees need only comply with permit conditions relating to discharges from the
municipal separate storm sewers for which they are operators.
(4) Discharges through large and medium municipal separate storm sewer systems. In addition to
meeting the requirements of paragraph (c) of this section, an operator of a storm water discharge
associated with industrial activity which discharges through a large or medium municipal separate
storm sewer system shall submit, to the operator of the municipal separate storm sewer system
receiving the discharge no later than May 15, 1991, or 180 days prior to commencing such
discharge: the name of the facility; a contact person and phone number; the location of the
discharge; a description, including Standard Industrial Classification, which best reflects the
principal products or services provided by each facility; and any existing NPDES permit number.
(5) Other municipal separate storm sewers. The Director may issue permits for municipal separate
storm sewers that are designated under paragraph (a)(1)(v) of this section on a system -wide
basis, jurisdiction -wide basis, watershed basis or other appropriate basis, or may issue permits
for individual discharges.
(6) Non -municipal separate storm sewers. For storm water discharges associated with industrial
activity from point sources which discharge through a non -municipal or non -publicly owned
separate storm sewer system, the Director, in his discretion, may issue: a single NPDES permit,
with each discharger a co-permittee to a permit issued to the operator of the portion of the system
that discharges into waters of the United States; or, individual permits to each discharger of storm
water associated with industrial activity through the non -municipal conveyance system.
(i) All storm water discharges associated with industrial activity that discharge through a storm
water discharge system that is not a municipal separate storm sewer must be covered by an
individual permit, or a permit issued to the operator of the portion of the system that
discharges to waters of the United States, with each discharger to the non -municipal
conveyance a co-permittee to that permit.
(ii) Where there is more than one operator of a single system of such conveyances, all operators
of storm water discharges associated with industrial activity must submit applications.
(iii) Any permit covering more than one operator shall identify the effluent limitations, or other
permit conditions, if any, that apply to each operator.
(7) Combined sewer systems. Conveyances that discharge storm water runoff combined with
municipal sewage are point sources that must obtain NPDES permits in accordance with the
procedures of Sec. 122.21 and are not subject to the provisions of this section.
(8) Whether a discharge from a municipal separate storm sewer is or is not subject to regulation
under this section shall have no bearing on whether the owner or operator of the discharge is
eligible for funding under title II, title III or title VI of the Clean Water Act. See 40 CFR part 35,
subpart I, appendix A(b)H.2.j.
(9)
(i) On and after October 1, 1994, for discharges composed entirely of storm water, that are not
required by paragraph (a)(1) of this section to obtain a permit, operators shall be required to
obtain a NPDES permit only if:

40 CFR 122
(A) The discharge is from a small MS4 required to be regulated pursuant to Sec. 122.32;
(B) The discharge is a storm water discharge associated with small construction activity
pursuant to paragraph (b)(15) of this section;
(C) The Director, or in States with approved NPDES programs either the Director or the EPA
Regional Administrator, determines that storm water controls are needed for the
discharge based on wasteload allocations that are part of "total maximum daily loads"
(TMDLs) that address the pollutant(s) of concern; or
(D) The Director, or in States with approved NPDES programs either the Director or the EPA
Regional Administrator, determines that the discharge, or category of discharges within a
geographic area, contributes to a violation of a water quality standard or is a significant
contributor of pollutants to waters of the United States.
(ii) Operators of small MS4s designated pursuant to paragraphs (a)(9)(i)(A), (a)(9)(i)(C), and
(a)(9)(i)(D) of this section shall seek coverage under an NPDES permit in accordance with
Secs. 122.33 through 122.35. Operators of non -municipal sources designated pursuant to
paragraphs (a)(9)(i)(B), (a)(9)(i)(C), and (a)(9)(i)(D) of this section shall seek coverage under
an NPDES permit in accordance with paragraph (c)(1) of this section.
(iii) Operators of storm water discharges designated pursuant to paragraphs (a)(9)(i)(C) and
(a)(9)(i)(D) of this section shall apply to the Director for a permit within 180 days of receipt of
notice, unless permission for a later date is granted by the Director (see Sec. 124.52(c) of this
chapter).
(b) Definitions.
(1) Co-permittee means a permittee to a NPDES permit that is only responsible for permit conditions
relating to the discharge for which it is operator.
(2) Illicit discharge means any discharge to a municipal separate storm sewer that is not composed
entirely of storm water except discharges pursuant to a NPDES permit (other than the NPDES
permit for discharges from the municipal separate storm sewer) and discharges resulting from fire
fighting activities.
(3) Incorporated place means the District of Columbia, or a city, town, township, or village that is
incorporated under the laws of the State in which it is located.
(4) Large municipal separate storm sewer system means all municipal separate storm sewers that
are either:
(i) Located in an incorporated place with a population of 250,000 or more as determined by the
1990 Decennial Census by the Bureau of the Census (Appendix F of this part); or
(ii) Located in the counties listed in appendix H, except municipal separate storm sewers that are
located in the incorporated places, townships or towns within such counties; or
(iii) Owned or operated by a municipality other than those described in paragraph (b)(4) (i) or (ii)
of this section and that are designated by the Director as part of the large or medium
municipal separate storm sewer system due to the interrelationship between the discharges
of the designated storm sewer and the discharges from municipal separate storm sewers
described under paragraph (b)(4) (i) or (11) of this section, In making this determination the
Director may consider the following factors:
(A) Physical interconnections between the municipal separate storm sewers;
(B) The location of discharges from the designated municipal separate storm sewer relative
to discharges from municipal separate storm sewers described in paragraph (b)(4)(i) of
this section;
(C) The quantity and nature of pollutants discharged to waters of the United States;
(D) The nature of the receiving waters; and
(E) Other relevant factors; or
(iv) The Director may, upon petition, designate as a large municipal separate storm sewer
system, municipal separate storm sewers located within the boundaries of a region defined
by a storm water management regional authority based on a jurisdictional, watershed, or
other appropriate basis that includes one or more of the systems described in paragraph
NW M. (ii). (iii) of this section.
5 ' a Tr muniei al a crate storrrt sewer outfall[ or " a or outfall" (means a m"u"niei apse a�at
1 p s p ( m j p�_l? ,�__

40 CFR 122
(6) Major outfall means a major municipal separate storm sewer outfall.
(7) Medium municipal separate storm sewer system means all municipal separate storm sewers that
are either:
(i) Located in an incorporated place with a population of 100,000 or more but less than 250,000,
as determined by the 1990 Decennial Census by the Bureau of the Census (Appendix G of
this part); or
(ii) Located in the counties listed in appendix I, except municipal separate storm sewers that are
located in the incorporated places, townships or towns within such counties; or
(iii) Owned or operated by a municipality other than those described in paragraph (b)(7) (i) or (ii)
of this section and that are designated by the Director as part of the large or medium
municipal separate storm sewer system due to the interrelationship between the discharges
of the designated storm sewer and the discharges from municipal separate storm sewers
described under paragraph (b)(7) (i) or (ii) of this section. In making this determination the
Director may consider the following factors:
(A) Physical interconnections between the municipal separate storm sewers;
(B) The location of discharges from the designated municipal separate storm sewer relative
to discharges from municipal separate storm sewers described in paragraph (b)(7)(i) of
this section;
(C) The quantity and nature of pollutants discharged to waters of the United States;
(D) The nature of the receiving waters; or
(E) Other relevant factors; or
(iv) The Director may, upon petition, designate as a medium municipal separate storm sewer
system, municipal separate storm sewers located within the boundaries of a region defined
by a storm water management regional authority based on a jurisdictional, watershed, or
other appropriate basis that includes one or more of the systems described in paragraphs
(b)(7) (i), (ii), (iii) of this section.
(8) Municipal separate storm sewer means a conveyance or system of conveyances (including roads
with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made
channels, or storm drains):
(i) Owned or operated by a State, city, town, borough, county, parish, district, association, or
other public body (created by or pursuant to State law) having jurisdiction over disposal of
sewage, industrial wastes, storm water, or other wastes, including special districts under
State law such as a sewer district, flood control district or drainage district, or similar entity, or
an Indian tribe or an authorized Indian tribal organization, or a designated and approved
management agency under section 208 of the CWA that discharges to waters of the United
States;
(ii) Designed or used for collecting or conveying storm water;
(iii) Which is not a combined sewer; and
iv Which is not Qart of a Publicly Owned Treatment Works POTW as defined at 40 CFR 122.2.
(9) ! utfa_I_I means a point source as defined b.y 40 CFR 1�22.2 at the point where a mu�ieipal sepaaratf
(10)Overburden means any material of any nature, consolidated or unconsolidated, that overlies a
mineral deposit, excluding topsoil or similar naturally -occurring surface materials that are not
disturbed by mining operations.
(11)Runoff coefficient means the fraction of total rainfall that will appear at a conveyance as runoff.
(12)Significant materials includes, but is not limited to: raw materials; fuels; materials such as
solvents, detergents, and plastic pellets; finished materials such as metallic products; raw

40 CFR 122
materials used in food processing or production; hazardous substances designated under section
101(14) of CERCLA; any chemical the facility is required to report pursuant to section 313 of title
III of SARA; fertilizers; pesticides; and waste products such as ashes, slag and sludge that have
the potential to be released with storm water discharges.
(13)Storm water means storm water runoff, snow melt runoff, and surface runoff and drainage.
(14)Storm water discharge associated with industrial activity means the discharge from any
conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing, processing or raw materials storage areas at an industrial plant. The term does
not include discharges from facilities or activities excluded from the NPDES program under this
part 122. For the categories of industries identified in this section, the term includes, but is not
limited to, storm water discharges from industrial plant yards; immediate access roads and rail
lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-
products used or created by the facility; material handling sites; refuse sites; sites used for the
application or disposal of process waste waters (as defined at part 401 of this chapter); sites used
for the storage and maintenance of material handling equipment; sites used for residual
treatment, storage, or disposal; shipping and receiving areas; manufacturing buildings; storage
areas (including tank farms) for raw materials, and intermediate and final products; and areas
where industrial activity has taken place in the past and significant materials remain and are
exposed to storm water. For the purposes of this paragraph, material handling activities include
storage, loading and unloading, transportation, or conveyance of any raw material, intermediate
product, final product, by-product or waste product. The term excludes areas located on plant
lands separate from the plant's industrial activities, such as office buildings and accompanying
parking lots as long as the drainage from the excluded areas is not mixed with storm water
drained from the above described areas. Industrial facilities (including industrial facilities that are
federally, State, or municipally owned or operated that meet the description of the facilities listed
in paragraphs (b)(14)(i) through (xi) of this section) include those facilities designated under the
provisions of paragraph (a)(1)(v) of this section. The following categories of facilities are
considered to be engaging in "industrial activity" for purposes of paragraph (b)(14):
(i) Facilities subject to storm water effluent limitations guidelines, new source performance
standards, or toxic pollutant effluent standards under 40 CFR subchapter N (except facilities
with toxic pollutant effluent standards which are exempted under category (xi) in paragraph
(b)(14) of this section);
(ii) Facilities classified as Standard Industrial Classifications 24 (except 2434), 26 (except 265
and 267), 28 (except 283), 29, 311, 32 (except 323), 33, 3441, 373;
(iii) Facilities classified as Standard Industrial Classifications 10 through 14 (mineral industry)
including active or inactive mining operations (except for areas of coal mining operations no
longer meeting the definition of a reclamation area under 40 CFR 434.11(1) because the
performance bond issued to the facility by the appropriate SMCRA authority has been
released, or except for areas of non -coal mining operations which have been released from
applicable State or Federal reclamation requirements after December 17, 1990) and oil and
gas exploration, production, processing, or treatment operations, or transmission facilities
that discharge storm water contaminated by contact with or that has come into contact with,
any overburden, raw material, intermediate products, finished products, byproducts or waste
products located on the site of such operations; (inactive mining operations are mining sites
that are not being actively mined, but which have an identifiable owner/operator; inactive
mining sites do not include sites where mining claims are being maintained prior to
disturbances associated with the extraction, beneficiation, or processing of mined materials,
nor sites where minimal activities are undertaken for the sole purpose of maintaining a mining
claim);
(iv) Hazardous waste treatment, storage, or disposal facilities, including those that are operating
under interim status or a permit under subtitle C of RCRA;
(v) Landfills, land application sites, and open dumps that receive or have received any industrial
wastes (waste that is received from any of the facilities described under this subsection)
including those that are subject to regulation under subtitle D of RCRA;

40 CFR 122
(vi) Facilities involved in the recycling of materials, including metal scrapyards, battery
reclaimers, salvage yards, and automobile junkyards, including but limited to those classified
as Standard Industrial Classification 5015 and 5093;
(vii) Steam electric power generating facilities, including coal handling sites;
(viii)Transportation facilities classified as Standard Industrial Classifications 40, 41, 42 (except
4221-25), 43, 44, 45, and 5171 which have vehicle maintenance shops, equipment cleaning
operations, or airport deicing operations. Only those portions of the facility that are either
involved in vehicle maintenance (including vehicle rehabilitation, mechanical repairs, painting,
fueling, and lubrication), equipment cleaning operations, airport deicing operations, or which
are otherwise identified under paragraphs (b)(14) (i)-(vii) or (ix) -(xi) of this section are
associated with industrial activity;
(ix) Treatment works treating domestic sewage or any other sewage sludge or wastewater
treatment device or system, used in the storage treatment, recycling, and reclamation of
municipal or domestic sewage, including land dedicated to the disposal of sewage sludge
that are located within the confines of the facility, with a design flow of 1.0 mgd or more, or
required to have an approved pretreatment program under 40 CFR part 403. Not included are
farm lands, domestic gardens or lands used for sludge management where sludge is
beneficially reused and which are not physically located in the confines of the facility, or areas
that are in compliance with section 405 of the-CWA;
(x) Construction activity including clearing, grading and excavation, except operations that result
in the disturbance of less than five acres of total land area. Construction activity also includes
the disturbance of less than five acres of total land area that is a part of a larger common plan
of development or sale if the larger common plan will ultimately disturb five acres or more;
(xi) Facilities under Standard Industrial Classifications 20, 21, 22, 23, 2434, 25, 265, 267, 27,
283, 285, 30, 31 (except 311), 323, 34 (except 3441), 35, 36, 37 (except 373), 38, 39, and
4221-25;
(15)Storm water discharge associated with small construction activity means the discharge of storm
water from:
(i) Construction activities including clearing, grading, and excavating that result in land
disturbance of equal to or greater than one acre and less than five acres. Small construction
activity also includes the disturbance of less than one acre of total land area that is part of a
larger common plan of development or sale if the larger common plan will ultimately disturb
equal to or greater than one and less than five acres. Small construction activity does not
include routine maintenance that is performed to maintain the original line and grade,
hydraulic capacity, or original purpose of the facility. The Director may waive the otherwise
applicable requirements in a general permit for a storm water discharge from construction
activities that disturb less than five acres where:
(A) The value of the rainfall erosivity factor ("R" in the Revised Universal Soil Loss Equation)
is less than five during the period of construction activity. The rainfall erosivity factor is
determined in accordance with Chapter 2 of Agriculture Handbook Number 703,
Predicting Soil Erosion by Water: A Guide to Conservation Planning With the Revised
Universal Soil Loss Equation (RUSLE), pages 21-64, dated January 1997. The Director
of the Federal Register approves this incorporation by reference in accordance with 5
U.S.0 552(a) and 1 CFR part 51. Copies may be obtained from EPA's Water Resource
Center, Mail Code RC4100, 401 M St. SW, Washington, DC 20460. A copy is also
available for inspection at the U.S. EPA Water Docket, 401 M Street SW, Washington,
DC 20460, or the Office of the Federal Register, 800 N. Capitol Street N.W. Suite 700,
Washington, DC. An operator must certify to the Director that the construction activity will
take place during a period when the value of the rainfall erosivity factor is less than five;
or
(B) Storm water controls are not needed based on a "total maximum daily load" (TMDL)
approved or established by EPA that addresses the pollutant(s) of concern or, for non -
impaired waters that do not require TMDLs, an equivalent analysis that determines
allocations for small construction sites for the pollutant(s) of concern or that determines
that such allocations are not needed to protect water quality based on consideration of

40 CFR 122
existing in -stream concentrations, expected growth in pollutant contributions from all
sources, and a margin of safety. For the purpose of this paragraph, the pollutant(s) of
concern include sediment or a parameter that addresses sediment (such as total
suspended solids, turbidity or siltation) and any other pollutant that has been identified as
a cause of impairment of any water body that will receive a discharge from the
construction activity. The operator must certify to the Director that the construction activity
will take place, and storm water discharges will occur, within the drainage area
addressed by the TMDL or equivalent analysis.
(11) Any other construction activity designated by the Director, or in States with approved NPDES
programs either the Director or the EPA Regional Administrator, based on the potential for
contribution to a violation of a water quality standard or for significant contribution of
pollutants to waters of the United States.
Exhibit 1 to Sec. 122.26(b)(15)--Summary of Coverage of "Storm Water Discharges Associated with Small
Construction Activity" Under the NPDES Storm Water Program
--------------------------------------------------------------------------------------------------------------------------------------------
Automatic Designation: Construction activities that Required Nationwide Coverage. result in a land
disturbance of equal to or greater than one acre and less than five acres.
Construction activities disturbing less than one acre if part of a larger common
plan of development or sale with a planned disturbance of equal to or greater
than one acre and less than five acres. (see Sec. 122.26(b)(15)(i).)
Potential Designation:
Construction activities that result in a land disturbance of less than one
Optional Evaluation and
acre based on the potential for contribution to a violation of a water
Designation by the
quality standard or for significant contribution of pollutants.(see Sec.
NPDES Permitting
122.26(b)(15)(ii).)
Authority or EPA Regional
Administrator.
Potential Waiver: Waiver from
Any automatically designated construction activity where the operator
Requirements as Determined
certifies: (1) A rainfall erosivity factor of less than five, or (2) That the
by the NPDES Permitting
activity will occur within an area where controls are not needed based
Authority.,
on a TMDL or, for non -impaired waters that do not require a TMDL, an equivalent
analysis for the pollutant(s) of concern. (see Sec. 122.26(b)(15)(i).)
(16)Small municipal separate storm sewer system means all separate storm sewers that are:
(i) Owned or operated by the United States, a State, city, town, borough, county, parish, district,
association, or other public body (created by or pursuant to State law) having jurisdiction over
disposal of sewage, industrial wastes, storm water, or other wastes, including special districts
under State law such as a sewer district, flood control district or drainage district, or similar
entity, or an Indian tribe or an authorized Indian tribal organization, or a designated and
approved management agency under section 208 of the CWA that discharges to waters of
the United States.
(ii) Not defined as "large" or "medium" municipal separate storm sewer systems pursuant to
paragraphs (b)(4) and (b)(7) of this section, or designated under paragraph (a)(1)(v) of this
section.
(iii) This term includes systems similar to separate storm sewer systems in municipalities, such
as systems at military bases, large hospital or prison complexes, and highways and other
thoroughfares. The term does not include separate storm sewers in very discrete areas, such
as individual buildings.
(17)Small MS4 means a small municipal separate storm sewer system.
(18)Municipal separate storm sewer system means all separate storm sewers that are defined as
"large" or "medium" or "small" municipal separate storm sewer systems pursuant to paragraphs
(b)(4), (b)(7), and (b)(16) of this section, or designated under paragraph (a)(1)(v) of this section.
(19)MS4 means a municipal separate storm sewer system.

40 CFR 122
(20)Uncontrolled sanitary landfill means a landill or open dump, whether in operation or closed, that
does not meet the requirements for runon or runoff controls established pursuant to subtitle D of
the Solid Waste Disposal Act.
(c) Application requirements for storm water discharges associated with industrial activity and storm
water discharges associated with small construction activity—
(1 } Individual application. Dischargers of storm water associated with industrial activity and with small
construction activity are required to apply for an individual permit or seek coverage under a
promulgated storm water general permit. Facilities that are required to obtain an individual permit
or any dischage of storm water which the Director is evaluating for designation (see Sec.
124.52(c) of this chapter) under paragraph (a)(1)(v) of this section and is not a municipal storm
sewer, shall submit an NPDES application in accordance with the requirements of Sec. 122.21 as
modified and supplemented by the provisions of this paragraph.
(i) Except as provided in Sec. 122.26(c)(1) (ii)-(iv), the operator of a storm water discharge
associated with industrial activity subject to this section shall provide:
(A) A site map showing topography (or indicating the outline of drainage areas served by the
outfall(s) covered in the application if a topographic map is unavailable) of the facility
including: each of its drainage and discharge structures; the drainage area of each storm
water outfall; paved areas and buildings within the drainage area of each storm water
outfall, each past or present area used for outdoor storage or disposal of significant
materials, each existing structural control measure to reduce pollutants in storm water
runoff, materials loading and access areas, areas where pesticides, herbicides, soil
conditioners and fertilizers are applied, each of its hazardous waste treatment, storage or
disposal facilities (including each area not required to have a RCRA permit which is used
for accumulating hazardous waste under 40 CFR 262.34); each well where fluids from
the facility are injected underground; springs, and other surface water bodies which
receive storm water discharges from the facility;
(B) An estimate of the area of impervious surfaces (including paved areas and building roofs)
and the total area drained by each outfall (within a mile radius of the facility) and a
narrative description of the following: Significant materials that in the three years prior to
the submittal of this application have been treated, stored or disposed in a manner to
allow exposure to storm water; method of treatment, storage or disposal of such
materials; materials management practices employed, in the three years prior to the
submittal of this application, to minimize contact by these materials with storm water
runoff; materials loading and access areas; the location, manner and frequency in which
pesticides, herbicides, soil conditioners and fertilizers are applied; the location and a
description of existing structural and non-structural control measures to reduce pollutants
in storm water runoff; and a description of the treatment the storm water receives,
including the ultimate disposal of any solid or fluid wastes other than by discharge;
(C) A certification that all outfalls that should contain storm water discharges associated with
industrial activity have been tested or evaluated for the presence of non -storm water
discharges which are not covered by a NPDES permit; tests for such non -storm water
discharges may include smoke tests, fluorometric dye tests, analysis of accurate
schematics, as well as other appropriate tests. The certification shall include a description
of the method used, the date of any testing, and the on -site drainage.points that were
directly observed during a test;
(D) Existing information regarding significant leaks or spills of toxic or hazardous pollutants at
the facility that have taken place within the three years prior to the submittal of this
application;
(E) Quantitative data based on samples collected during storm events and collected in
accordance with Sec. 122.21 of this part from all outfalls containing a storm water
discharge associated with industrial activity for the following parameters:
(1) Any pollutant limited in an effluent guideline to which the facility is subject;
(2) Any pollutant listed in the facility's NPDES permit for its process wastewater (if the
facility is operating under an existing NPDES permit);

40 CFR 122
(3) Oil and grease, pH, BOD5, COD, TSS, total phosphorus, total Kjeldahl nitrogen, and
nitrate plus nitrite nitrogen;
(4) Any information on the discharge required under Sec. 122.21(g)(7)(vi) and (vii);
(5) Flow measurements or estimates of the flow rate, and the total amount of discharge
for the storm event(s) sampled, and the method of flow measurement or estimation;
and
(6) The date and duration (in hours) of the storm event(s) sampled, rainfall
measurements or estimates of the storm event (in inches) which generated the
sampled runoff and the duration between the storm event sampled and the end of the
previous measurable (greater than 0.1 inch rainfall) storm event (in hours);
(F) Operators of a discharge which is composed entirely of storm water are exempt from the
requirements of Sec. 122.21 (g)(2), (g)(3), (g)(4), (g)(5), (g)(7)(iii), (g)(7)(iv), (g)(7)(v), and
(g)(7)(viii); and
(G) Operators of new sources or new discharges (as defined in Sec. 122.2 of this part) which
are composed in part or entirely of storm water must include estimates for the pollutants
or parameters listed in paragraph (c)(1)(i)(E) of this section instead of actual sampling
data, along with the source of each estimate. Operators of new sources or new
discharges composed in part or entirely of storm water must provide quantitative data for
the parameters listed in paragraph (c)(1)(i)(E) of this section within two years after
commencement of discharge, unless such data has already been reported under the
monitoring requirements of the NPDES permit for the discharge. Operators of a new
source or new discharge which is composed entirely of storm water are exempt from the
requirements of Sec. 122.21 (k)(3)(ii), (k)(3)(iii), and (k)(5).
(ii) An operator of an existing or new storm water discharge that is associated with industrial
activity solely under paragraph (b)(14)(x) of this section or is associated with small
construction activity solely under paragraph (b)(15) of this section, is exempt from the
requirements of Sec. 122.21(g) and paragraph (c)(1)(i) of this section. Such operator shall
provide a narrative description of:
(A) The location (including a map) and the nature of the construction activity;
(B) The total area of the site and the area of the site that is expected to undergo excavation
during the life of the permit;
(C) Proposed measures, including best management practices, to control pollutants in storm
water discharges during construction, including a brief description of applicable State and
local erosion and sediment control requirements;
(D) Proposed measures to control pollutants in storm water discharges that will occur after
construction operations have been completed, including a brief description of applicable
State or local erosion and sediment control requirements;
(E) An estimate of the runoff coefficient of the site and the increase in impervious area after
the construction addressed in the permit application is completed, the nature of fill
material and existing data describing the soil or the quality of the discharge; and
(F) The name of the receiving water.
(iii) The operator of an existing or new discharge composed entirely of storm water from an oil or
gas exploration, production, processing, or treatment operation, or transmission facility is not
required to submit a permit application in accordance with paragraph (c)(1)(i) of this section,
unless the facility:
(A) Has had a discharge of storm water resulting in the discharge of a reportable quantity for
which notification is or was required pursuant to 40 CFR 117.21 or 40 CFR 302.6 at anytime
since November 16, 1987; or
(B) Has had a discharge of storm water resulting in the discharge of a reportable quantity for
which notification is or was required pursuant to 40 CFR 110.6 at any time since November
16, 1987; or
(C) Contributes to a violation of a water quality standard.
(iv) The operator of an existing or new discharge composed entirely of storm water from a mining
operation is not required to submit a permit application unless the discharge has come into
contact with, any overburden, raw material, intermediate products, finished product,
byproduct or waste products located on the site of such operations.

40 CFR 122
(v) Applicants shall provide such other information the Director may reasonably require under
Sec. 122.21(g)(13) of this part to determine whether to issue a permit and may require any
facility subject to paragraph (c)(1)(ii) of this section to comply with paragraph (c)(1)(i) of this
section.
(2) [Reserved]
EE
operator of a discharge from a large or medium municipal separate storm sewer or a municipal
separate storm sewer that is designated by the Director under paragraph (a)(1)(v) of this section, may
submit a jurisdiction -wide or system -wide permit application. Where more than one public entity owns
or operates a municipal separate storm sewer within a geographic area (including adjacent or
interconnected municipal separate storm sewer systems), such operators may be a coapplicant to the
same application. Permit applications for discharges from large and medium municipal storm sewers
or municipal storm sewers designated under paragraph (a)(1)(v) of this section shall include;
(1) Part 1. Part 1 of the application shall consist of;
(i) General information. The applicants' name, address, telephone number of contact person,
ownership status and status as a State or local government entity.
(ii) Legal authority. A description of existing legal authority to control discharges to the municipal
separate storm sewer system. When existing legal authority is not sufficient to meet the
criteria provided in paragraph (d)(2)(i) of this section, the description shall list additional
authorities as will be necessary to meet the criteria and shall include a schedule and
commitment to seek such additional authority that will be needed to meet the criteria.
(iii) Source identification.
(A) A description of the historic use of ordinances, guidance or other controls which limited
the discharge of non -storm water discharges to any Publicly Owned Treatment Works
serving the same area as the municipal separate storm sewer system.
(B) A USGS 7.5 minute topographic map (or equivalent topographic map with a scale
between 1:10,000 and 1:24,000 if cost effective) extending one mile beyond the service
boundaries of the municipal storm sewer system covered by the permit application. The
following information shall be provided:
(1) The location of known municipal storm sewer system outfalls discharging to waters of
the United States;
(2) A description of the land use activities (e.g. divisions indicating undeveloped,
residential, commercial, agricultural and industrial uses) accompanied with estimates
of population densities and projected growth for a ten year period within the drainage
area served by the separate storm sewer. For each land use type, an estimate of an
average runoff coefficient shall be provided;
(3) The location and a description of the activities of the facility of each currently
operating or closed municipal landfill or other treatment, storage or disposal facility
for municipal waste;
(4) The location and the permit number of any known discharge to the municipal storm
sewer that has been issued a NPDES permit;
(5) The location of major structural controls for storm water discharge (retention basins,
detention basins, major infiltration devices, etc.); and
(6) The identification of publicly owned parks, recreational areas, and other open lands.
(iv) Discharge characterization.
(A) Monthly mean rain and snow fall estimates (or summary of weather bureau data) and the
monthly average number of storm events.
(B) Existing quantitative data describing the volume and quality of discharges from the
municipal storm sewer, including a description of the outfalls sampled, sampling
procedures and analytical methods used.
(C) A list of water bodies that receive discharges from the municipal separate storm sewer
system, including downstream segments, lakes and estuaries, where pollutants from the
system discharges may accumulate and cause water degradation and a brief description
of known water quality impacts. At a minimum, the description of impacts shall include a
description of whether the water bodies receiving such discharges have been:
10

40 CFR 122
(1) Assessed and reported in section 305(b) reports submitted by the State, the basis for
the assessment (evaluated or monitored), a summary of designated use support and
attainment of Clean Water Act (CWA) goals (fishable and swimmable waters), and
causes of nonsupport of designated uses;
(2) Listed under section 304(I)(1)(A)(i), section 304(I)(1)(A)(ii), or section 304(I)(1)(B) of
the CWA that is not expected to meet water quality standards or water quality goals;
(3) Listed in State Nonpoint Source Assessments required by section 319(a) of the CWA
that, without additional action to control nonpoint sources of pollution, cannot
reasonably be expected to attain or maintain water quality standards due to storm
sewers, construction, highway maintenance and runoff from municipal landfills and
municipal sludge adding significant pollution (or contributing to a violation of water
quality standards);
(4) Identified and classified according to eutrophic condition of publicly owned lakes
listed in State reports required under section 314(a) of the CWA (include the
following: A description of those publicly owned lakes for which uses are known to be
impaired; a description of procedures, processes and methods to control the
discharge of pollutants from municipal separate storm sewers into such lakes; and a
description of methods and procedures to restore the quality of such lakes);
(5) Areas of concern of the Great Lakes identified by the International Joint Commission;
(6) Designated estuaries under the National Estuary Program under section 320 of the
CWA;
(7) Recognized by the applicant as highly valued or sensitive waters;
(8) Defined by the State or U.S. Fish and Wildlife Services's National Wetlands Inventory
as wetlands; and
(9) Found to have pollutants in bottom sediments, fish tissue or biosurvey data.
(D) Field screening. Results of a field screening analysis for illicit connections and illegal
dumping for either selected field screening points or major outfalls covered in the permit
application. At a minimum, a screening analysis shall include a narrative description, for
either each field screening point or major outfall, of visual observations made during dry
weather periods. If any flow is observed, two grab samples shall be collected during a 24
hour period with a minimum period of four hours between samples. For all such samples,
a narrative description of the color, odor, turbidity, the presence of an oil sheen or surface
scum as well as any other relevant observations regarding the potential presence of non -
storm water discharges or illegal dumping shall be provided. In addition, a narrative
description of the results of a field analysis using suitable methods to estimate pH, total
chlorine, total copper, total phenol, and detergents (or surfactants) shall be provided
along with a description of the flow rate. Where the field analysis does not involve
analytical methods approved under 40 CFR part 136, the applicant shall provide a
description of the method used including the name of the manufacturer of the test method
along with the range and accuracy of the test. Field screening points shall be either major
outfalls or other outfall points (or any other point of access such as manholes) randomly
located throughout the storm sewer system by placing a grid over a drainage system map
and identifying those cells of the grid which contain a segment of the storm sewer system
or major outfall. The field screening points shall be established using the following
guidelines and criteria:
(1) A grid system consisting of perpendicular north -south and east -west lines spaced
11141 mile apart shall be overlayed on a map of the municipal storm sewer system,
creating a series of cells;
(2) All cells that contain a segment of the storm sewer system shall be identified; one
field screening point shall be selected in each cell; major outfalls may be used as
field screening points;
(3) Field screening points should be located downstream of any sources of suspected
illegal or illicit activity;
(4) Field screening points shall be located to the degree practicable at the farthest
manhole or other accessible location downstream in the system, within each cell;
11

40 CFR 122
however, safety of personnel and accessibility of the location should be considered in
making this determination;
(5) Hydrological conditions; total drainage area of the site; population density of the site;
traffic density; age of the structures or buildings in the area; history of the area; and
land use types;
(6) For medium municipal separate storm sewer systems, no more than 250 cells need
to have identified field screening points; in large municipal separate storm sewer
systems, no more than 500 cells need to have identified field screening points; cells
established by the grid that contain no storm sewer segments will be eliminated from
consideration; if fewer than 250 cells in medium municipal sewers are created, and
fewer than 500 in large systems are created by the overlay on the municipal sewer
map, then all those cells which contain a segment of the sewer system shall be
subject to field screening (unless access to the separate storm sewer system is
impossible); and
(7) Large or medium municipal separate storm sewer systems which are unable to utilize
the procedures described in paragraphs (d)(1)(iv)(D) (1) through (6) of this section,
because a sufficiently detailed map of the separate storm sewer systems is
unavailable, shall field screen no more than 500 or 250 major outfalls respectively (or
all major outfalls in the system, if less); in such circumstances, the applicant shall
establish a grid system consisting of north -south and east -west lines spaced 11141
mile apart as an overlay to the boundaries of the municipal storm sewer system,
thereby creating a series of cells; the applicant will then select major outfalls in as
many cells as possible until at least 500 major outfalls (large municipalities) or 250
major outfalls (medium municipalities) are selected; a field screening analysis shall
be undertaken at these major outfalls.
(E) Characterization plan. Information and a proposed program to meet the requirements of
paragraph (d)(2)(iii) of this section. Such description shall include: the location of outfalls
or field screening points appropriate for representative data collection under paragraph
(d)(2)(iii)(A) of this section, a description of why the outfall or field screening point is
representative, the seasons during which sampling is intended, a description of the
sampling equipment. The proposed location of outfalls or field screening points for such
sampling should reflect water quality concerns (see paragraph (d)(1)(iv)(C) of this
section) to the extent practicable.
(v) Management programs.
(A) A description of the existing management programs to control pollutants from the
municipal separate storm sewer system. The description shall provide information on
existing structural and source controls, including operation and maintenance measures
for structural controls, that are currently being implemented. Such controls may include,
but are not limited to: Procedures to control pollution resulting from construction activities;
floodplain management controls; wetland protection measures; best management
practices for new subdivisions; and emergency spill response programs. The description
may address controls established under State law as well as local requirements.
(B) A description of the existing program to identify illicit connections to the municipal storm
sewer system. The description should include inspection procedures and methods for
detecting and preventing illicit discharges, and describe areas where this program has
been implemented.
(vi) Fiscal resources.
(A) A description of the financial resources currently available to the municipality to complete
part 2 of the permit application. A description of the municipality's budget for existing
storm water programs, including an overview of the municipality's financial resources and
budget, including overall indebtedness and assets, and sources of funds for storm water
programs.
(2) Part 2. Part 2 of the application shall consist of:
(i) Adequate legal authority. A demonstration that the applicant can operate pursuant to legal
authority established by statute, ordinance or series of contracts which authorizes or enables
the applicant at a minimum to:
12

40 CFR 122
(A) Control through ordinance, permit, contract, order or similar means, the contribution of
pollutants to the municipal storm sewer by storm water discharges associated with
industrial activity and the duality of storm water discharged from sites of industrial activity;
(B) Prohibit through ordinance, order or similar means, illicit discharges to the municipal
separate storm sewer;
(C) Control through ordinance, order or similar means the discharge to a municipal separate
storm sewer of spills, dumping or disposal of materials other than storm water;
(D) Control through interagency agreements among coapplicants the contribution of
pollutants from one portion of the municipal system to another portion of the municipal
system;
(E) Require compliance with conditions in ordinances, permits, contracts or orders; and
(F) Carry out all inspection, surveillance and monitoring procedures necessary to determine
compliance and noncompliance with permit conditions including the prohibition on illicit
(iii) Characterization data. When "quantitative data" for a pollutant are required under paragraph
(d)(2)(111)(A)(3) of this section, the applicant must collect a sample of effluent in accordance
with 40 CFR 122,21(g)(7) and analyze it for the pollutant in accordance with analytical
methods approved under part 136 of this chapter, When no analytical method is approved the
applicant may use any suitable method but must provide a description of the method. The
applicant must provide information characterizing the quality and quantity of discharges
covered in the permit application, including:
(A) Quantitative data from representative outfalls designated by the Director (based on
information received in part 1 of the application, the Director shall designate between five
and ten outfalls or field screening points as representative of the commercial, residential
and industrial land use activities of the drainage area contributing to the system or, where
there are less than five outfalls covered in the application, the Director shall designate all
outfalls) developed as follows:
(1) For each outfall or field screening point designated under this subparagraph,
samples shall be collected of storm water discharges from three storm events
occurring at least one month apart in accordance with the requirements at Sec.
122,21(g)(7) (the Director may allow exemptions to sampling three storm events
when climatic conditions create good cause for such exemptions);
(2) A narrative description shall be provided of the date and duration of the storm
event(s) sampled, rainfall estimates of the storm event which generated the sampled
discharge and the duration between the storm event sampled and the end of the
previous measurable (greater than 0.1 inch rainfall) storm event;
(3) For samples collected and described under paragraphs (d)(2)(iii) (A)(1) and (A)(2) of
this section, quantitative data shall be provided for: the organic pollutants listed in
Table II; the pollutants listed in Table III (toxic metals, cyanide, and total phenols) of
appendix D of 40 CFR part 122, and for the following pollutants:
Total suspended solids (TSS)
Total dissolved solids (TDS)
COD
BOD5
Oil and grease
Fecal coliform
Fecal streptococcus
pH
Total Kjeldahl nitrogen
13

40 CFR 122
Nitrate plus nitrite
Dissolved phosphorus
Total ammonia plus organic nitrogen
Total phosphorus
(4) Additional limited quantitative data required by the Director for determining permit
conditions (the Director may require that quantitative data shall be provided for
additional parameters, and may establish sampling conditions such as the location,
season of sample collection, form of precipitation (snow melt, rainfall) and other
parameters necessary to insure representativeness);
(B) Estimates of the annual pollutant load of the cumulative discharges to waters of the
United States from all identified municipal outfalls and the event mean concentration of
the cumulative discharges to waters of the United States from all identified municipal
outfalls during a storm event (as described under Sec. 122.21(c)(7)) for BOD5, COD,
TSS, dissolved solids, total nitrogen, total ammonia plus organic nitrogen, total
phosphorus, dissolved phosphorus, cadmium, copper, lead, and zinc. Estimates shall be
accompanied by a description of the procedures for estimating constituent loads and
concentrations, including any modelling, data analysis, and calculation methods;
(C) A proposed schedule to provide estimates for each major outfall identified in either
paragraph (d)(2)(ii) or (d)(1)(iii)(B)(1) of this section of the seasonal pollutant load and of
the event mean concentration of a representative storm for any constituent detected in
any sample required under paragraph (d)(2)(iii)(A) of this section; and
(D) A proposed monitoring program for representative data collection for the term of the
permit that describes the location of outfalls or field screening points to be sampled (or
the location of instream stations), why the location is representative, the frequency of
sampling, parameters to be sampled, and a description of sampling equipment.
(iv) Proposed management program. A proposed management program covers the duration of
the permit. It shall include a comprehensive planning process which involves public
participation and where necessary intergovernmental coordination, to reduce the discharge of
pollutants to the maximum extent practicable using management practices, control
techniques and system, design and engineering methods, and such other provisions which
are appropriate. The program shall also include a description of staff and equipment available
to implement the program. Separate proposed programs may be submitted by each
coapplicant. Proposed programs may impose controls on a systemwide basis, a watershed
basis, a jurisdiction basis, or on individual outfalls. Proposed programs will be considered by
the Director when developing permit conditions to reduce pollutants in discharges to the
maximum extent practicable. Proposed management programs shall describe priorities for
implementing controls. Such programs shall be based on:
(A) A description of structural and source control measures to reduce pollutants from runoff
from commercial and residential areas that are discharged from the municipal storm
sewer system that are to be implemented during the life of the permit, accompanied with
an estimate of the expected reduction of pollutant loads and a proposed schedule for
implementing such controls. At a minimum, the description shall include:
(1) A description of maintenance activities and a maintenance schedule for structural
controls to reduce pollutants (including floatables) in discharges from municipal
separate storm sewers;
(2) A description of planning procedures including a comprehensive master plan to
develop, implement and enforce controls to reduce the discharge of pollutants from
municipal separate storm sewers which receive discharges from areas of new
development and significant redevelopment. Such plan shall address controls to
reduce pollutants in discharges from municipal separate storm sewers after
construction is completed. (Controls to reduce pollutants in discharges from
municipal separate storm sewers containing construction site runoff are addressed in
paragraph (d)(2)(iv)(D) of this section;
(3) A description of practices for operating and maintaining public streets, roads and
highways and procedures for reducing the impact on receiving waters of discharges
14

40 CFR 122
from municipal storm sewer systems, including pollutants discharged as a result of
deicing activities;
(4) A description of procedures to assure that flood management projects assess the
impacts on the water quality of receiving water bodies and that existing structural
flood control devices have been evaluated to determine if retrofitting the device to
provide additional pollutant removal from storm water is feasible;
(5) A description of a program to monitor pollutants in runoff from operating or closed
municipal landfills or other treatment, storage or disposal facilities for municipal
waste, which shall identify priorities and procedures for inspections and establishing
and implementing control measures for such discharges (this program can be
coordinated with the program developed under paragraph (d)(2)(iv)(C) of this
2
(B) A description of a program, including a schedule, to detect and remove (or require the
discharger to the municipal separate storm sewer to obtain a separate NPDES permit for)
illicit discharges and improper disposal into the storm sewer. The proposed program shall
include:
(1) A description of a program, including inspections, to implement and enforce an
ordinance, orders or similar means to prevent illicit discharges to the municipal
separate storm sewer system; this program description shall address all types of illicit
discharges, however the following category of non -storm water discharges or flows
shall be addressed where such discharges are identified by the municipality as
sources of pollutants to waters of the United States: water line flushing, landscape
irrigation, diverted stream flows, rising ground waters, uncontaminated ground water
infiltration (as defined at 40 CFR 35.2005(20)) to separate storm sewers,
uncontaminated pumped ground water, discharges from potable water sources,
foundation drains, air conditioning condensation, irrigation water, springs, water from
crawl space pumps, footing drains, lawn watering, individual residential car washing,
flows from riparian habitats and wetlands, dechlorinated swimming pool discharges,
and street wash water (program descriptions shall address discharges or flows from
fire fighting only where such discharges or flows are identified as significant sources
of pollutants to waters of the United States);
(2) A description of procedures to conduct on -going field screening activities during the
life of the permit, including areas or locations that will be evaluated by such field
screens;
(3) A description of procedures to be followed to investigate portions of the separate
storm sewer system that, based on the results of the field screen, or other
appropriate information, indicate a reasonable potential of containing illicit discharges
or other sources of non -storm water (such procedures may include: sampling
procedures for constituents such as fecal coliform, fecal streptococcus, surfactants
(MBAS), residual chlorine, fluorides and potassium; testing with fluorometric dyes; or
conducting in storm sewer inspections where safety and other considerations allow.
Such description shall include the location of storm sewers that have been identified
for such evaluation);
(4) A description of procedures to prevent, contain, and respond to spills that may
discharge into the municipal separate storm sewer;
(5) A description of a program to promote, publicize, and facilitate public reporting of the
presence of illicit discharges or water quality impacts associated with discharges from
municipal separate storm sewers;
15

40 CFR 122
(6) A description of educational activities, public information activities, and other
appropriate activities to facilitate the proper management and disposal of used oil
and toxic materials; and
(7) A description of controls to limit infiltration of seepage from municipal sanitary sewers
to municipal separate storm sewers stems where necessary;
(C) ik description of .a program to monitor And'control pollutants in storm water discharges t
unicipal; systems from municipal lanif'dfills'hazardous�wki;' *reatrh nt, disposal an
ecovery=fad ilities ind steal facilitie thhat a,e-�u ect to section„313 of title'III of th
uperfu'nd'Amend ents and. R�eauthortzatkn"�Rct of 1986'.(SARA), and industrial facilitie
hat the;:munic,.ipal permit applicant determmesiare'ticontributmg'a substantial ollutan
oading to the mun �palst ormsewer,: ystem. The program shall
1 Identifyfpnor,ities a�proedures for ins ections and establishin and im lementin
ontroI measures;§R .M66idischaFa6s
Describe a monitoring'°program #or4stormwater discharges associated with th
ndustnalrfacilities dentifiediin pa'rag-raph,(d)(2)(iv)(C) of this. section, to b
mplemented, d r,i �gthe term` ofsthe pe mjit ,including the submission of quantitate
Jata bAthe follow g constituents any pollutants Iimitedn effluent guideline
�ubcate§g§or'ies �h re"app�I�cable; anyApolluitziht listed i�ja ezistir g IVPDES perm
3 facljty 'bil.and grease`,C®D, pH BOD5�'rTSS total phosphorus total Kteldah
iitragen4 nitratepl19�ustnte'nitrogen and an informatiom'on discharges required
inder Sec: 122 21(d.0) (viYand NM
(D) A description of a program to implement and maintain structural and non-structural best
management practices to reduce pollutants in storm water runoff from construction sites
to the municipal storm sewer system, which shall include:
(1) A description of procedures for site planning which incorporate consideration of
potential water quality impacts;
(2) A description of requirements for nonstructural and structural best management
practices;
(3) A description of procedures for identifying priorities for inspecting sites and enforcing
control measures which consider the nature of the construction activity, topography,
and the characteristics of soils and receiving water quality; and
(4) A description of appropriate educational and training measures for construction site
operators.
(v) Assessment of controls. Estimated reductions in loadings of pollutants from discharges of
municipal storm sewer constituents from municipal storm sewer systems expected as the
result of the municipal storm water quality management program. The assessment shall also
identify known impacts of storm water controls on ground water.
(vi) Fiscal analysis. For each fiscal year to be covered by the permit, a fiscal analysis of the
necessary capital and operation and maintenance expenditures necessary to accomplish the
activities of the programs under paragraphs (d)(2) (iii) and (iv) of this section. Such analysis
shall include a description of the source of funds that are proposed to meet the necessary
expenditures, including legal restrictions on the use of such funds.
(vii) Where more than one legal entity submits an application, the application shall contain a
description of the roles and responsibilities of each legal entity and procedures to ensure
effective coordination.
(viii)Where requirements under paragraph (d)(1)(iv)(E), (d)(2)(ii), (d)(2)(iii)(B) and (d)(2)(iv) of this
section are not practicable or are not applicable, the Director may exclude any operator of a
discharge from a municipal separate storm sewer which is designated under paragraph
(a)(1)(v), (b)(4)(ii) or (b)(7)(ii) of this section from such requirements. The Director shall not
exclude the operator of a discharge from a municipal separate storm sewer identified in
appendix F, G, H or I of part 122, from any of the permit application requirements under this
paragraph except where authorized under this section.
16

Draft Agenda - MS4 Audit
Winston-Salem, North Carolina
June 27 - 29, 2006
Tuesday, June 27th
A
8:30 - 10:00 am Opening Conference
Interview Winston-Salem representatives to obtain program overview.
Identify locations for the field component.
10:15 am - 12:00 pm Interviews and Records Review related to
(1" team) Post -Construction Storm Water Management in Areas of New Development and
Significant Redevelopment (Section 7.5)
(2"d team) Illicit Discharge Detection and Elimination Program (Section 7.3)
1:00 - 4:30 pm Interviews and Records Review related to
(1s'team) Flood Control Projects (Section 7.6.7) and Construction Site Runoff
Program (Section 7.4)
(2"d team) Illicit Discharge Detection and Elimination Program (continued) and X
Industrial Program
Wednesday, June 28th
8:30 am - 12:00 pm Interviews and Records Review related to
(1"team) Public Education and Public Participation/Involvement (Sections 7.1 and 7.2)
(2"d team) Pollution Prevention/Good Housekeeping for Municipal Operations (All Sections 7.6
except Section 7.6.7)
1:00 - 4:30 pm Field Component
0" team) Observe MS4 staff conduct industrial inspection.
(2Id team) Observe MS4 staff conduct construction site inspection.
Thursday, June 29th
8:00 am - 12:00 pm Interviews and Records Review
(151 team) Monitoring Programs
Complete any outstanding interviews and review records as needed.
8:00 am - 11:00 am Field Component
(2"d team) Observe MS4 staff conduct municipal operations inspection.
1.00 pm Closing Conference

Winston-Salem, NC
Pollution Prevention/Good Housekeeping for Municipal Operations
[Permit Section 1.13.(4)(b)] The City will implement programs to address the contribution of
pollutants to the MS4 from commercial and residential areas including planning, monitoring,
education and operation and maintenance activities.
[Permit Section 1.13.(4)(d)] The City will implement inspection and monitoring programs for
stormwater structures ............. These programs will include provisions to assure compliance
through enforcement mechanisms.
Inspections and report generation of City -owned facilities and municipal operations
Person(s) Interviewed:
What is the status of the City inspecting its facilities and operations list in Section 7.6.2 on page
34 of the SWMP? How many of the 18 listed facilities have been inspected? What is the City's
schedule for completing these inspections?
Has the City developed structural and non-structural BMPs for the inspected facilities? If so:
• Are the structural and non-structural BMPs documented?
• Has the City provided the facility or operations with a timeframe for implementing the
BMPs?
Section 7.6.1 - BMP 1 (Inspections and Report Generation)
Section 7.3.1 - BMP 8 (Municipal Housekeeping Inspections)
Training
For the facilities that have been inspected and structural and non-structural BMPs developed, has
the City conducted training sessions for the facility staff tailored to the potential pollutant
contributing processes that are occurring on a day-to-day basis?
When were the training sessions held and who conducted the training?
Section 7.61 - BMP 2 (Training of employees)
Has the City prepared Department -specific educational materials to train City staff to incorporate
pollution prevention techniques into their daily activities? (Jerry, This may be the same as the
above, but this BMP was included in the public education section and is worded slightly
different.)
What topics are covered in the training?
When were training sessions held and who attended?
Section 7.1.1 - BMP 12 (Municipal Good Housekeeping Training and Education)
Does the City conduct training for all new employees?
What topics are covered?
When were training sessions held and who attended?

Section 7.1.1 _ BMP 16 (City of Winston-Salem University)
Does the City have training documentation for the all of the above training sessions (new
employees, employees at the municipal facilities or operations, any other training related to
incorporating pollution prevention into daily activities)?
Maintenance and Inspections
Has the City inventoried the type and location of these structures? Have they been included in
the City's mapping system? (Jerry, You may get the answers to this question during the
1DDE interview when discussing the inventory and mapping.)
Describe the City's operation and maintenance practices/procedures and schedule for the
following control structures owned or operated by the City:
• Municipal detention ponds, retention basins, and impoundments
• Open drainage channels
• Storm sewer inlets
Storm sewer lines
Catch basin, siphons, and other structures.
How often are the structures inspected?
How often are the structures maintained (e.g., trash and debris removed)?
Are records kept of the material and debris removed during maintenance?
How are the removed trash and debris disposed or
How is maintenance conducted?
Has the City determined if any structural BMPs are needed in areas of high floatables and debris
collection? If so, what type of structural BMPs and at which location were structural BMPs
installed?
Section 7.6.1 - BMP 3 (Structural Controls)
Now does the City respond to structural control maintenance complaints? How does the City
prioritize maintenance needs?
Yard Waste Program
Describe the City's yard waste collection and seasonal leaf collection program.
Are the programs curbside pick-up? If so:
• What is the schedule for collection of yard wastes?
• What is the schedule for leaf collection?
What is done with the yard wastes and leaves that are collected?
Does the City track the amount of yard wastes and leaves collected?
How does the City advertise the program?
Section 7.6.1 - BMP 4 (Yard Waste Program)
Recycling Program
-2-

Describe the City's recycling program. Is there a permanent collection facility for dropoff or is
there curbisde pick-up?
What types of materials are collected?
What is done with the materials collected?
Does the City track the amount of materials collected for recycling?
How does the City advertise the program?
Section 7.6.1 - BMP S (Recycling Program)
Public Street and Roadway Maintenance
Person(s) Interviewed:
Snow and ice management
Describe your snow and ice management procedures.
What type of deicing agents are used? If salt is used, have alternative materials been
investigated?
Where and how are these materials stored? What BMPs are used for the storage areas?
Does the City track the locations and volumes of deicing agents, sand, or other materials used?
Is the material picked up after the snow/ice event has ended?
Street sweeping
What is the schedule/frequency for street sweeping (on roads, streets)?
What types of sweepers are used (wet, dry)?
How is the debris disposed of? Are sweeping wastes recycled? If debris is dewatered, how. is
this done?
Are records kept of the amount of debris collected?
How does the City use the data/information for these activities to evaluate program effectiveness
(e.g., are the data used to prioritize cleaning activities or to target areas for outreach based on
type and volume of materials removed)?
Section 7.6.1 - BMP 7 (Street Sweeping Program)
Roadway Maintenance
Person(s) Interviewed:
What types of street, public roads, and highway operation and maintenance practices and
procedures are performed by the City?
Are BMPs used by field crews to minimize stormwater impacts during road maintenance or
repair activities?
What types of BMPs are used? Discuss the BMPs used for such activities as
• Ditch cleaning
• Sidewalk repair
• Asphalt patching
• Curb and gutter repair
• Street striping
all

Sign painting.
Does the City use contractors for street/roadway maintenance? If so:
Does the City require contractors to incorporate storm water BMPs into their activities?
— How are these requirements implemented (RFP, contract language)?
— Has the City adopted officially adopted BMP standards for contractors?
Pesticide, Herbicide, and Fertilizer (PHF) Application
Person(s) Interviewed:
What is the status of the City's pesticide, herbicide, and fertilizer program?
Does the City have written procedures (SQPs for PHF handling, use, storage, and disposal)?
Does the City use Integrated Pest Management (IPM)?
What chemicals are used? Does the City use Restricted Use Pesticides (RUPs)?
Does the City track the amounts of pesticides applied?
Where are the chemicals stored? Are appropriate BMPs used (i.e., secondary containment)?
Are City applicators certified/licensed?
What other training do City staff have?
Does the City use contractors for PHF application? if so:
-- Does the City require contractors to incorporate storm water BMPs into their activities?
— How are these requirements implemented (RFP, contract language)?
— Has the City adopted officially adopted BMP standards for contractors?
Does the City have a fertilizer application plan?
Does the City track the amounts of fertilizer used?
-4-

Winston-Salem, NC
Illicit Discharge Detection and Elimination
[Permit Section l.X(4)(b)] The City will implement the appropriate components of the
Stormwater Program to assure that to the maximum extent practicable, non-stormwater
discharges, illicit connections, spills and illegal dumping into the MS4 are prohibited.
[Permit Section I.B.(3)] The City will continue to locate and identify additional sources of
stormwater discharge not previously identified in the permit application process or previous
permit terms. This includes the location and characterization of major outfalls from the MS4 and
any activities or facilities discharging to the MS4 that were not previously located but are
expected to contribute pollutants to the MS4. (Jerry, This is included below under dry
weather screening questions.)
[Permit Section 1.13.(4)(a)] The City will implement education, training and outreach programs
designed to reach all areas of the City's community and which explain the various impacts of
stormwater runoff and how it can affect surface water quality. These programs will address ways
of removing potential pollutants by emphasizing local involvement in recycling programs;
proper disposal of hazardous materials and used motor oil; proper use of pesticides, herbicides
and fertilizers; and noticing and reporting of potential pollutant problems. (Jerry, The ones
bolded and italicized are the programs covered in this section. I am covering the public
application of PHFs in public education.)
[Permit Section I.13(4)(c)] Components of the SWQMP will include: implementation of
programs to detect and remove sources of illicit connections to the MS4 and to remove sources
of non-stormwater discharge. These programs will include development of legal authority and
ordinances needed for inspections and enforcement.
Storm Sewer System Map
Person(s) Interviewed:
Section 7.3.1 - BMP 15 (Stormwater Sewer Inventory): Does the City have a map of the
storm system?
Section 7.3.1 - BMP 16 (Watershed Mapping and Routing)
Which of the following does the City map include:
• outfalls
• stormwater management facilities (City -owned, privately -owned residential, and
privately -owned commercial/industrial)
• storm drain inlets
• storm sewer lines
• catch basins
• receiving water bodies
• watershed information?
-1-

Is the map readily available to illicit discharge personnel for tracing potential sources of illicit
discharges? Is in the map in paper copy or also in a GIS?
How does the City update its map?
Regulatory Mechanism and Enforcement
What ordinance or regulation has the City's authority to prohibit non-stonnwater discharges?
• What exclusions are included in the ordinance or regulation?
• What enforcement authority is available?
• Has an enforcement escalation plan been developed?
Detection and Elimination
Person(s) Interviewed:
Dry weather screening
Has the City maintained an inventory of all MS4 outfalls and whether the outfall is major or
minor?
Has the City continued to locate and identify additional sources of stormwater discharge not
previously identified in the permit application process or previous permit terms? (This includes
the location and characterization of major outfalls from the MS4 and any activities or
facilities discharging to the MS4 that were not previously located but are expected to
contribute pollutants to the MS4.)
Does the City have a dry weather screening program? If so,
• how are screening sites identified?
• are areas of the MS4 prioritized based on incidents of illicit discharges, land use,
dumping reports, etc.?
Does the City have written procedures for its field screening program?
If dry weather flows are present, are they sampled? If so, what parameters are being tested?
Does the City have a database or other method for tracking locations of illicit discharges, spills,
and illegal dumping?
• Does the database track dry weather monitoring or screening data?
Activities to detect illicit discharges
What other activities are used to detect illicit discharges?
Section 7.3.1 - BMP 9 (Visual Observations): Are stormwater personnel actively watching
for illicit discharges during the course of their job duties?
Section 7.3.1 - BMP 3 (Infrared Photography): Has the City conducted thermal
photography in order to identify illicit discharges? If so, what part(s) of the City were
photographed? When was this done? What were the results of the photography?
Section 7.31 - BMP 7 (Stream Walking): Do City staff conduct stream walking of each
urban watershed annually for detecting illicit discharges, illicit connections, and stream
erosion, etc.? Does the City have documentation of the stream walking (completed forms,
etc.)?
Are other field staff within City organizations used to observe/identify illicit discharges (e.g.,
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Street Maintenance)? If so:
• What type of training do these City staff have (i.e., how to identify unusual flows or
connections to the storm drain system and who to call if such an occurrence arises)?
• What training was conducted in'2005/2006?
Does the City have written procedures for investigation of suspected illicit discharges (e.g., to
trace the source of the illicit discharge)?
• Is sampling conducted? What parameters are tested?
• What equipment is used for further investigation (e.g., televising)?
Does the City use a form or checklist to document its efforts to locate and stop illicit discharges?
What enforcement actions has the City taken related to illicit discharges:
• Notice of violation
• Compliance schedule to eliminate the discharge?
Spill Response and Prevention
Person(s) Interviewed:
Describe the spill prevention, containment and response program.
Who (what agencies) are responsible for responding to spills?
Do you have written spill response procedures that clearly indicate who is responsible for
responding to spills and emergency situations?
Do City staff have spill containment supplies in their vehicles?
Does the City have the ability to collect cleanup and abatement costs from the responsible party?
Does the City have an established reporting protocol to ensure that the appropriate staff are
notified of all spills?
How does the City train its employees in spill prevention and spill response?
Promote Public Reporting of Illicit Discharges and Improper Disposal
Person(s) Interviewed:
Does the City have a phone number for reporting illicit discharges?
Section 7.3.1 - BMP 11 (SW Pollution Hotline): Can citizens call stormwater employees to
report illegal activities?
Section 7.4.1 - BMP 4 (SW Hotline) Do citizens report sediment and construction site
runoff problems via the hotline?
Section 7.1.1 - BMP 13 (Stormwater Hotline)
Section 7.2.1 - BMP S (Stormwater Hotline)
Does the City track the number of calls received?
What types of outreach materials are available to promote public reporting? How are these
materials distributed?
-3-

r

Describe the Citizen Request Management System .
Section 7.3.1- BMP 10 (Citizen Request Management System): Can the public access the
City's homepage to provide notice of illicit discharges?
Section 7.4.1 - BMP 5 (Citizen Request Management System): Can citizens or City staff use
the CRM to report construction site runoff problems?
Section 7.1.1 - BMP 14 (Citizen Request Management System): Does the City respond to all
queries from the CRM system?
Section 7.3.1 - BMP 12 (SW Public Education): Does the City conduct storm drain
stenciling?
What is the City's program for responding to citizen complaints of illicit discharges?
• How does the City track its illicit discharge complaints and responses?
• What data are tracked?
Section 7.3.1 - BMP 2 (Respond to Spills or Dumping): Does the City respond to all illicit
discharge or dumping complaints within 24 hours of first knowledge of occurrence?
Household Hazardous Wastes and Used Motor Oil
Person(s) Interviewed:
Describe the City's household hazardous wastes program.
Is there a permanent collection facility for dropoff? Is the facility in continuous operations or are
there scheduled events for HHW and used motor oil collection?
What types of HHW are accepted?
What is done with the HHW collected?
Does the City track the amount of HHW collected?
How does the City advertise the program?
Section 7.3.1 - BMP 14 (3RC - HHW Disposal): Does the City have free disposal for its
citizens?
Section 7.6.1 - BMP 6 (311C Program)
Describe the City's program for proper disposal of used motor oil.
Who is the target audience?
Does the City have educational materials/information regarding the proper disposal of used oil.
How are these materials distributed?
Control of Sanitary Seepage into the MS4
Person(s) Interviewed:
Does the City have a program to mitigate or prevent sanitary sewer overflows (SSOs) from
entering the MS4? Has the City conducted any studies or evaluations to determine sanitary
sewers are causing water quality problems?
Have flow pathways from SSO locations to catch basins or other points of entry to the MS4 been
idcntified?
-4-

Have spill prevention and cleanup plans been prepared?
Does the City have written procedures to ensure that the MS4 is protected from an SSO or
sewage spill? Do the procedures include protection of the storm drain system during and after
the cleanup of the SSO or sewage spill?
Does the City implement a reporting protocol to ensure that all spills and overflows are reported
to the appropriate State authority or the City department designated to collect and report this
information?
If the City has residential homes with septic tanks, how does the City educate homeowners about
proper maintenance of these septic systems?
How many SSOs did the City experience within the past year? How many of these SSOs have
entered the MS4?
Section 7.3.1 BMP 6 (Sewer Overflow Historical Mapping and Detection): Describe the
City's monthly monitoring at 46 strategic locations for elevated pollutants of concern.
52

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Winston-Salem, NC
Industrial Runoff Program
[Permit Section I.B.(4)(d)] The City will implement inspection and monitoring programs for
industrial activities ............. These programs will include provisions to assure compliance
through enforcement mechanisms.
Regulatory Mechanism
Person(s) Interviewed:
Does the City have the authority to require industrial and commercial facilities to implement
stormwater BMPs?
Does the City have the authority to conduct inspections? What ordinance provides this
authority?
What types of facilities are covered under this legal authority? Are there any exemptions?
Facility Inventory
Has the City completed its inventory of industrial/commercial facilities discharging to the
stormwater system?
What types of facilities are included on the inventory?
What sources were used to create the inventory:
• Facilities that filed NOIs for EPA or State industrial general permit coverage
• SIUs within the pretreatment program
• Business licenses
• Phone book
• Water billing
• Drive-bys?
Does the City periodically check to see if new facilities have filed an NOI?
What is the process for notifying the State of non -filers?
How is the inventory updated? How often?
Best Management Practices Education
Has the City assessed commercial facilities for actual and potential sources of pollutants? If so,
which type of commercial facilities were assessed?
Section 7.3.1 - BMP 13 (BMP Education with Commercial Facilities) Were these facilities
shown alternative practices (including structural and non-structural BMPs)?
How was this done:
• Development of outreach and education materials
• Referring the facilities to available technical guidances
• Training sessions
• Working one -on -on at the commercial facility?
When and where were these activities conducted?
-I-

r ,

Winston-Salem, NC
Industrial Runoff Program
[Permit Section I.B.(4)(d)j The City will implement inspection and monitoring programs for
industrial activities.. ......... .. These programs will include provisions to assure compliance
through enforcement mechanisms.
Regulatory Mechanism
Person(s) Interviewed:
Does the City have the authority to require industrial and commercial facilities to implement
stormwater BMPs?
Does the City have the authority to conduct inspections? What ordinance provides this
authority?
What types of facilities are covered under this legal authority? Are there any exemptions?
Facility Inventory
Has the City completed its inventory of industrial1commercial facilities discharging to the
stormwater system?
What types of facilities are included on the inventory?
What sources were used to create the inventory:
• Facilities that filed NOIs for EPA or State industrial general permit coverage
• SIUs within the pretreatment program
• Business licenses
• Phone book
• Water billing
• Drive-bys?
Does the City periodically check to see if new facilities have filed an NOI?
What is the process for notifying the State of non -filers?
How is the inventory updated? How often?
Best Management Practices Education
Has the City assessed commercial facilities for actual and potential sources of pollutants? If so,
which type of commercial facilities were assessed?
Section 7.3.1- BMP 13 (BMP Education with Commercial Facilities) Were these facilities
shown alternative practices (including structural and non-structural BMPs)?
How was this done:
• Development of outreach and education materials
• Referring the facilities to available technical guidances
• Training sessions
• Working one -on -on at the commercial facility?
When and where were these activities conducted?
4-

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Inspections
Who performs the industrial inspections?
• How often are industrial and commercial facilities inspected?
• How is the frequency determined?
• Are the facilities prioritized for inspections?
Section 7.3.1 - BMP 1 (Industrial Inspections): Conduct 12 industrial surface water
inspections annually of NPDES-permitted facilities. Prepare written report. Coordinate
with local DENR representative.
Do the City inspectors use a checklist?
How is the inspection documented? Is a report written?
Does the City verify NPDES permit coverage for facilities?
What criteria are used to evaluate the site (i.e., determine compliance)? What types of things do
the City inspectors observe/look for during an inspection? Do the City inspectors check
paperwork (e.g., SWPPP, site map, self -inspection reports)?
How long does a typical inspection take?
What types of training do the City inspectors have?
Enforcement
What types of enforcement actions are provided in the City's regulatory mechanism?
Does the City have a written enforcement plan or procedures which include an established
escalated policy?
How does the City determine if sites have returned to compliance?
How many enforcement actions has the City taken in 2005/2006?
Do City staff feel that the City's enforcement authority is adequate to achieve compliance?
At what point are non-compliance cases referred to the State? How many have been referred in
the past 12 months?
IN

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Inspections
Who performs the industrial inspections?
• How often are industrial and commercial facilities inspected?
• How is the frequency determined?
• Are the facilities prioritized for inspections?
Section 7.3.1 - BMP 1 (Industrial Inspections): Conduct 12 industrial surface water
inspections annually of NPDES-permitted facilities. Prepare written report. Coordinate
with local DENR representative.
Do the City inspectors use a checklist?
How is the inspection documented? Is a report written?
Does the City verify NPDES permit coverage for facilities?
What criteria are used to evaluate the site (i.e., determine compliance)? What types of things do
the City inspectors observe/look for during an inspection? Do the City inspectors check
paperwork (e.g., SWPPP, site map, self -inspection reports)?
How long does a typical inspection take?
What types of training do the City inspectors have?
Enforcement
What types of enforcement actions are provided in the City's regulatory mechanism?
Does the City have a written enforcement plan or procedures which include an established
escalated policy?
How does the City determine if sites have returned to compliance?
How many enforcement actions has the City taken in 200512006?
Do City staff feel that the City's enforcement authority is adequate to achieve compliance?
At what point are non-compliance cases referred to the State? How many have been referred in
the past 12 months?
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aft A Ln r`L'
1

Draft Agenda - MS4 Audit
Winston-Salem, North Carolina
June 27 - 29, 2006
Tuesday, June 27th
8:30 -10:00 am Opening Conference
Interview Winston-Salem representatives to obtain program overview.
Identify locations for the field component.
10:15 am - 12:00 pm Interviews and Records Review related to
0" team) Post -Construction Storm Water Management in Areas of New Development and
Significant Redevelopment (Section 7.5)
(2"d team) Illicit Discharge Detection and Elimination Program (Section 7.3)
1:00 - 4:30 pm Interviews and Records Review related to
0st team) Flood Control Projects (Section 7.6.7) and Construction Site Runoff -7 3', awl—`
Program (Section 7.4)
(2nd team) Illicit Discharge Detection and Elimination Program (continued) and��
Industrial Program
Wednesday, June 28th
8:30 am - 12:00 pm Interviews and Records Review related to
(1 st team) Public Education and Public Participation/involvement (Sections 7.1 and 7.2)
-- (2"d team) Pollution Prevention/Good Housekeeping for Municipal Operations (All Sections 7.6
except Section 7.6.7)
1:00 - 4:30 pm Field Component
(1st team) Observe MS4 staff conduct industrial inspection.
(2rld team) Observe MS4 staff conduct construction site inspection.
Thursday, June 29th
8:00 am -12:00 pm Interviews and Records Review
(1st team) Monitoring Programs
Complete any outstanding interviews and review records as needed.
8:00 am - 11:00 am Field Component
(2"d team) Observe MS4 staff conduct municipal operations inspection.
1:00 pm Closing Conference

Winston-Salem, NC
Construction Site Runoff Program
[Permit Section I.B.(4)(e)] The City will implement a program to reduce pollutants from
construction sites through site planning, education, training, and inspection and enforcement
mechanisms.
Regulatory Mechanism
Person(s) Interviewed:
What is the City's regulatory mechanism for requiring erosion and sediment control measures at
construction sites? What is the threshold for requiring erosion and sediment controls and
submission of an erosion and sediment control plan (e.g., one acre or greater)?
Section 7.4.1 - BMP 6 (Interim Construction site runoff controls): Did the City develop an
ordinance to require developers to manage the quantity of stormwater runoff during the
construction phase of development?
Plan Reviews
Person(s) Interviewed:
What are the City's plan review and approval procedures? Are these procedures documented?
In the City's procedures:
-- What are the review criteria and standards?
— Do the City reviewers use a checklist when reviewing plans?
— Do the City reviewers look for adequate erosion and sediment control measures
on the plans, what types of standard conditions or notes are included?
— Do the plan notes include prohibition of non-stormwater discharges?
— Do the City reviewers check whether other measures to address materials storage
and waste disposal are included on the plans?
Does the City verify whether the project applicant has submitted an NOT to the State before a
plan can be approved?
Does the City consider pollutants of concern or whether the project discharges to an impaired
water body when determining what type of erosion and sediment control measures are required?
Section 7.4.1 - BMP 1 (Construction Plan review and approval): Is the control plan
reviewed and approved by the Inspections Division prior to issuing a grading permit?
What type of training does the City staff related to the site plan review?
What training has been done in 200512006?
Site Inspections
Person(s) Interviewed:
How many erosion and sediment control inspectors does the City have? What part of the
organization are these inspectors located in?
Approximately how many inspections are conducted per year?
se

4

How does the City track its construction sites?
How does the City prioritize sites for inspection? What factors are used?
How often does the City inspect the sites?
Section 7.4.1 - BMP 2 (Construction site inspections): Do inspectors visit the sites on a
routine basis?
Does the City inspect sites during and immediately after wet weather events?
Does the City have written procedures for conducting inspections?
What criteria are used to evaluate a site (i.e., determine compliance)?
• What are the areas of primary concern and how does the inspector identify these?
• Does the City inspector use a checklist?
• Does the City inspector evaluate what the owner/operator committed to implement in its
SWMP?
• Does the construction site owner/operator provide information to the City on its
compliance with the State permit?
Does the City have criteria/qualifications for its inspectors? If so, what are these
criteria/qualifications?
What is the City's training plan for inspectors?
• What training has been conducted in 2005/2006?
Enforcement
What types of enforcement actions are provided in the City's regulatory mechanism?
Does the City have a written enforcement plan or procedures which include an established
escalated policy?
How does the City determine if sites have returned to compliance?
How many enforcement actions has the City taken in 2005/2006?
Do City staff feel that the City's enforcement authority is adequate to achieve compliance?
Training and Education for Construction Site Operators
What is the City's training plan for construction site operators? Does it include activities such as
distribution of outreach materials, seminars/training sessions, etc.?
If outreach materials were distributed, how were they distributed and how many copies were
distributed?
Section 7.4.1 - BMP 3 (Education materials and information to land developers): What and
how was it distributed (i.e., with grading permits)? To how many developers?
If seminars/training sessions were conducted, when was it conducted, how many participants
attended, and what topics were covered?
Has the City amended its education and training program for construction site operators to
incorporate revised rules and regulations?
City construction projects
Person(s) Interviewed:
-2-

Do City RFP or contracts include language specifying stormwater requirements?
Are inspection and maintenance requirements specified in the contract?
What oversight does the City implement to ensure that the contractor is implementing all
requirements as appropriate?
What penalties are in place to require compliance from the City's contractors?
-3-

Winston-Salem, NC
Flood Management Program
[Permit Section 1.13.(4)(d)] The City will implement inspection and monitoring programs for
industrial activities ............. These programs will include provisions to assure compliance
through enforcement mechanisms.
Person(s) Interviewed.
Describe the City's floodplain management program. What is the City's legal authority to
implement this program? (Section 7.6.7 of SWMP document)
What are the City's procedures for assessing the impact of new flood control projects (e.g., wet
or dry detention basins, stream channel modifications, or floodplain storage projects) on the
receiving water, stormwater quality, and stormwater quantity?
How does the City implement these procedures?
Does the City have an inventory of its flood management devices/structures?
What are the City's procedures for evaluating existing structural flood control devices to:
identify structures that could be enhanced by retrofitting with storm water quality features
evaluate the feasibility of retrofitting those structures based on consideration of factors
such as:
- type
- location
- watershed
- water quality benefits
- ownership
- public health
- cost?
What is the status of this evaluation? Were any retrofit projects identified?
if so, are these projects included in the City's capital improvement program?
Do the retrofit projects have budgets and schedules for implementation?
-1-

4
Winston-Salem, NC
Monitoring Program
[Permit Section I.B.(1)] The City will perform all wet weather sampling of representative outfalls
that was originally a component of the Part 2 application, until such time as 12 individual data
points are available. Wet weather sampling of representative outfalls may be discontinued
thereafter with alternative monitoring strategies implemented.
[Permit Section I.B.(5)] The City will implement monitoring efforts as outlined in the
Stormwater Program to prioritize areas of the program and to assess the effectiveness of program
components. These monitoring results will be used by the City to modify the program
components as necessary to accomplish the intent of the Stormwater Program. Results of the
monitoring program will be submitted to the State in accordance with Section LC of the Permit.
[Permit Section I.B.(6)] Monitoring programs in the context of the permit are not limited only to
conventional sampling in the form of sampling and analysis. Assessment of program
implementation, use of programs established by the Stormwater Program, etc. are also part of the
process. Sampling activities are required as part of the monitoring process in accordance with
the provisions outlined in the Stormwater Program.
Describe the City's monitoring program.
Characterization monitoring
Does it include monitoring of representative outfalls?
• How were these outfalls selected?
• What is the frequency of sampling?
• What parameters are analyzed? What sampling and analytical methods are used?
• Does the City have a written protocol/procedures for this sampling program?
• Who conducts the sampling? Have the sampling personnel been trained?
Ambient monitoring
Does it include in -stream ambient monitoring?
How were the sampling sites selected?
• Is sampling conducted both during dry weather and wet weather?
• What is the frequency of sampling?
• What parameters are analyzed? What sampling and analytical methods have been used?
• Does the City have a written protocol/procedures for this sampling program?
• Who conducts the sampling? Have the sampling personnel been trained?
Section 7.3.1 - BMP 4 (Ambient Sampling): Conduct dry weather composite sampling
quarterly at 15 sites. Conduct discharge calculation for pollutant loadings.
Section 7.3.1- BMP 5 (Storm Event Sampling): Conduct flow -weighted wet weather
composite samples annually at 15 sites.
• What are done with the monitoring results (e.g., have they been used to assess program
-1-

components)?
Does the City have documentation of the sampling process and results? What records are kept:
• analytical results
• date and duration (in hours) of storm event sampled
• rainfall measurements or estimates (in inches) of the storm event which generated the
sample runoff
• duration (in hours) of the storm event sampled and the end of the previous measurable
storm event (e.g., greater than 0.1 inch)?
• estimate of the flow of the discharge sampled?
What are the results of the sampling and analysis?
Has the City made any changes to the monitoring program?
Have the monitoring results been used to assess program components)?
-2-

Winston-Salem, NC
Post -Construction Storm Water Management in New Development and Significant
Redevelopment
[Permit Section I.B.(4)(d)] The City will implement inspection and monitoring programs for
stormwater structures ............. These programs will include provisions to assure compliance
through enforcement mechanisms.
Regulatory Mechanism
Person(s) Interviewed:
What ordinances or regulations contain the City's authority for requiring new significant
development and redevelopment to require post -construction controls on new development and
significant redevelopment sites?
How is new development/significant redevelopment defined in the ordinance and/or regulations?
• What is the threshold for the City to require post -construction BMPs for significant
development and redevelopment (e.g., one acre or more)?
Does the City's legal authority allow for exemptions?
Does the City's legal authority authorize the City to require stormwater management plans?
Describe how the City's watershed plans incorporate water quality planning.
Section 7.5.8 - BMP 1 (Ordinance Authority): Has the City developed and enacted the
ordinance?
Project review and approval
What are the City's project review and approval procedures?
Section 7.5.8 - BMP 2 (Design Review): Project review and approval process.
Are these procedures documented?
In the City's procedures:
• What are the review criteria and standards? What technical guidance does the City use
(e.g., BMP manual)?
• Are project applicants required to follow the technical manual?
What is the City's site development review process?
• Do the City reviewers use a checklist when reviewing plans?
• Do the City reviewers look for adequate BMPs on the plans, what types of
standard conditions or notes are included, and whether maintenance requirements
are specified?
• Does the City have different requirements for different types of development (e.g.,
gas stations, restaurants)?
Does the City consider pollutants of concern or whether the project discharges to an impaired
water body when determining what types of BMPs are required? For example, how does the City
consider stormwater draining to Yadkin River then High Rock Lake, which is nutrient sensitive
and currently has a TMDL in development for Chlorophyll A and turbidity?

Operation and Maintenance (Inspection and enforcement procedures)
Does the City have an inventory of its BMPs? Does it include both publicly -owned and
privately -owned BMPs? (Jerry will find out if these are on a GIS map during the IDDE
interview.)
How many privately -owned stormwater management structures are in the City?
What requirements has the City established that privately owned or operated stormwater
management structures (residential and commercial/industrial) are maintained?
Does the City require maintenance agreements?
Section 7.5.8 - BMP 3 (Maintenance and Operation): What is the City's process for
reviewing maintenance reports to ensure proper operation of stormwater management
structures?
Does the City inspect these structures prior to acceptance to ensure that they have been built
according to the approved plan?
If the City inspects the privately -owned structures, how often are inspections performed?
Enforcement
How does the City require proper maintenance and repair after inspection?
What types of enforcement actions are provided by the ordinance (e.g., NOV s)?
Is the City's enforcement authority limited (e.g., limit of dollars of fines)?
Has the City taken enforcement actions in instances where the responsible party is not
maintaining a structure?
Post -Construction Education
Section 7.5.8 - BMP 5 (Post -Construction Education). How does the City provide education
to the development and design community on new regulations and how to comply?
Does it include activities such as distribution of outreach materials, seminars/training sessions?
If outreach materials were distributed, how were they distributed and how many copies were
distributed?
If seminars/training sessions were conducted, when was it conducted, how many participants
attended, and what topics were covered?
Does the City have documentation of these activities?
Staff training plans
What type of training does the City staff related to:
• plan review
• inspection of development sites?
What training has been done in 2005/2006?
Fecal Coliform Source Control
Person(s) Interviewed:
How does the City coordinate with the Forsyth County Dept. of Public Health to reduce fecal
coliform inputs to the MS4? (Ask about this during Opening Conference.)
-2-

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What does the City do with respect to the oversight program to ensure proper operation and
maintenance of on -site wastewater treatment systems?
Section 7.5.8 - BMP 4 (Fecal Coliform Control): Has the City developed procedures with
the County Health Dept. to ensure proper septic operations?
What activities does the City conduct to implement structural BMPs that encourage the die -off of
fecal coliform bacteria to the maximum extent practicable?
How does the City -County Utilities Commission prioritize projects that include failing sections
of the sanitary sewers?
Also how does the City work with the CCUC to locate and resolve sanitary sewer overflows to
the MS4?
-3-

Draft Agenda - MS4 Audit
Winston-Salem, North Carolina
June 27 - 29, 2006
Tuesday, June 27th
S
8:30 - 10:00 am Opening Conference
Interview Winston-Salem representatives to obtain program overview.
Identify locations for the field component.
10:15 am - 12:00 pm Interviews and Records Review related to
0" team) Post -Construction Storm Water Management in Areas of New Development and
Significant Redevelopment (Section 7.5)
(2"d team) Illicit Discharge Detection and Elimination Program (Section 7.3)
1:00 - 4:30 pm Interviews and Records Review related to
(15'team) Flood Control Projects (Section 7.6.7) and Construction Site Runoff
Program (Section 7.4)
(2"d team) Illicit Discharge Detection and Elimination Program (continued) and
Industrial Program
Wednesday, June 28th
8:30 am - 12:00 pm Interviews and Records Review related to
(1" team) Public Education and Public Participation/Involvement (Sections 7.1 and 7.2)
(2"d team) Pollution Prevention/Good Housekeeping for Municipal Operations (All Sections 7.6
except Section 7.6.7)
1:00 - 4:30 pm Field Component
(151 team) Observe MS4 staff conduct industrial inspection.
(2"d team) Observe MS4 staff conduct construction site inspection.
Thursday, June 29th
8:00 am - 12:00 pm Interviews and Records Review
(151team) Monitoring Programs
Complete any outstanding interviews and review records as needed.
8:00 am - 11:00 am Field Component
(2"d team) Observe MS4 staff conduct municipal operations inspection.
1:00 pm Closing Conference

Pen -nit No. NCS000247
PART I
SECTION A: FINAL LIMITATIONS AND CONTROLS FOR MUNICIPAL STORMWATER DISCHARGES
During the period beginning on the effective date of the permit and lasting until
expiration, the City of Winston-Salem is authorized to discharge stormwater from the
municipal separate storm sewer system to waters of the Yadkin Pee -Dee River Basin.'
Such discharge will be controlled, limited and monitored in accordance with the City
of Winston-Salem's Comprehensive Stormwater Management Program, herein referred to
as the "Stormwater Program". The Stormwater Program includes applicable components
of the City of Winston-Salem's municipal separate storm sewer system NPDES permit
application, and their Stormwater Quality Management Plan, herein referred to as the
"SWQNP", and any approved modifications to the SWQMP.
(1) The permit cove-rs activities associated with the discharge of stormwater from
the municipal storm sewer system within the jurisdictional area of the City of
Winston-Salem and surrounding areas as appropriate to control potential pollution
from the storm sewer system. The permit applies to current and future.
jurisdictional areas of the city as well as areas that seek coverage under this
permit through interlocal or other similar agreements with the City of Winston-
Salem. Agreements for coverage under this permit must be approved by the Division
of Water Quality, herin referred to as the Division.
(2) The Division may deny or revoke coverage under this permit for separate
entities and require independent permit coverage as deemed necessary. In addition,
the City of Winston-Salem may petition the Division to revoke or deny coverage under
this permit for specific entities.
(3) The permit authorizes the point source discharge of stormwater runoff from the
municipal storm sewer system. In addition, discharges of non-stormwater are also
authorized through the municipal storm sewer of the City of Winston-Salem if such
discharges are:
(a) Permitted by, and in compliance with, an independent NPDES discharge permit
including discharges of process and non -process wastewater, and stormwater
associated with industrial activity; or
(b) Determined to be incidental non-stormwater flows that do not significantly
impact water quality and may include:
• water line flushing;
• landscape irrigation;
• diverted stream flows;
• rising groundwaters;
• uncontaminated groundwater infiltration;
• uncontaminated pumped groundwater;
• discharges from potable water sources;
• foundation drains,
• air conditioning condensate (commercial/residential);
• irrigation waters;
• springs;
• water from crawl space pumps;
• footing drains;
• lawn watering;
• residential car washing;
• flows from riparian habitats and wetlands;
• dechlorinated swimming pool discharges;
• street wash water;
• flows from emergency fire fighting.
The Division may require that non-stormwater flows of this type be
controlled by the city's Stormwater Program.
(4) The City of Winston-Salem will implement, manage and oversee all provisions of
its Stormwater Program to reduce pollutants discharged from the municipal separate
storm sewer system. This includes, but is not limited to, the following areas:
(a) The City of Winston-Salem will develop and maintain adequate legal
authorities to implement all provisions of the Stormwater Program. The
Page 1
&q ' 1005

Permit No. NCS000247
City of Winston-Salem will keep the Division advised of the status of
development of appropriate ordinances and legal authorities and will pursue
these authorities in accordance with the Stormwater Program. If major
modifications are proposed in the time line for development of these
authorities, the Division will be notified of the reasons and
justifications for these changes. The Division.may comment on these
modifications as deemed necessary to assure appropriate implementation of
the Stormwater Program.
(b) The City of Winston-Salem's Stormwater Program will be implemented and
managed such that the discharge of pollutants from the municipal storm
sewer system is controlled to the maximum extent practicable. It is
anticipated that in order to meet this provision, implementation of the
Stormwater Program will occur with emphasis given to priority areas and to
management measures and programs that are most effective and efficient at
varying stages of the plan's implementation.
(c) The City of Winston-Salem will implement the appropriate components of the
Stormwater Program to assure that, to the maximum extent practicable, non-
stormwater discharges, illicit connections, spills and illegal dumping into
the municipal storm sewer system are prohibited.
(d) The City of Winston-Salem will implement provisions of the Stormwater
Program as appropriate to monitor and assess the performance of the various
management measures that are a part of the Stormwater Program. This will
include, but is not limited to, the provisions of Part 1 Section C of this
permit and the applicable provisions of the City of Winston-Salem's
Stormwater Program.
(e) The City of Winston-Salem will maintain adequate funding and staffing to
implement and manage the provisions of the Stormwater Program.
(f) The City of Winston-Salem will implement appropriate education, training
and outreach programs to support the objectives of this stormwater
discharge permit and the City's Stormwater Program.
(5) The Division will review reports submitted by the City of Winston-Salem to
assure that the Stormwater Program is being developed and implemented appropriately
to address the components outlined. Such reports will be submitted in accordance
with the schedule outlined in Section C of this Part. The Division may require
modifications to any part of the City's Stormwater•Program where deficiencies are
found.
Page 2

Permit No. NCS000247
SECTION B: COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM IMPLEMENTATION
Under the authority of section 402(p) of the Clean Water Act and implementing
regulations 40 CFR Part 122.26, North Carolina General Statutes 143-215.1 and
implementing regulations 15A NCAC 2H .0100 and in accordance with the approved
Stormwater Program, all provisions contained and referenced in the Stormwater
Program are an enforceable part of this permit.
The City of Winston-Salem will develop and implement its approved Stormwater Program
in accordance with section 402(p)(3)(B) of the Clean Water Act, provisions outlined
by the Director, and the provisions of this Permit. The specific requirements of
section 402(p)(3)(B) of the Clean Water Act require that the City effectively
prohibit non-stormwater discharges to the City's storm sewer system and that
controls and management measures are implemented by the City to reduce the discharge
of pollutants from the storm sewer system to the maximum extent practical. In
addition to the components outlined in Section A of this part, the City of Winston-
Salem's Stormwater Program will include, but is not limited to, the following
components:
1) The City of Winston-Salem will perform all wet weather sampling of
representative outfalls that was originally a component of the Part 2 municipal
application, until such time as 12 individual data points are available. Wet
weather sampling of representative outfalls may be discontinued thereafter
where alternative monitoring strategies are implemented.
2) The City of Winston-Salem will pursue appropriate legal authorities and develop
necessary local ordinances to administer all components of the Stormwater
Program. Status of legal authority development will be provided to the
Division upon request, but at a minimum on an annual basis.
3) The City of Winston-Salem will continue to locate and identify additional
sources of stormwater discharge not previously identified in the permit
application process and the previous permit terms. This will include the
location and characterization of major outfalls from the municipal stormwater
system and of any activities or facilities discharging to the municipal system
that were not previously located but are expected to contribute pollutants to
the municipal storm sewer system.
4). The City of Winston-Salem will implement management programs as specified in
the SWQMP to control the discharge of pollutants from its storm sewer system
associated with stormwater runoff from commercial, residential, industrial and
construction areas and pollutants from non-stormwater discharges. These
programs will be implemented on a priority basis as determined and outlined by
the City of Winston-Salem in the SWQMP. The overall program implementation,
however, will be subject to, at a minimum, annual review by the Division to
determine implementation status and progression toward meeting the pollutant
control intent of the Stormwater Program. Components of the specific SWQMP
programs will include, but are not limited to:
(a) The implementation of education, training and outreach programs designed
to reach all areas of the City of Winston-Salem's community and which
explain the various impacts of stormwater runoff and how it can affect
surface water quality. These programs will address ways of removing
potential pollutants by emphasizing local involvement in recycling
programs; proper disposal of hazardous materials and used motor oil; the
proper use of herbicides, pesticides and fertilizers; and noticing and
reporting areas of potential pollution problems.
(b) The implementation of programs to address the contribution of pollutants
to the storm sewer system from commercial and residential areas
including planning, monitoring, education and operation and maintenance
activities.
(c) The implementation of programs to detect and remove sources of illicit
connections to the municipal storm sewer system and to remove sources of
non-stormwater discharge. These programs will include development of
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Permit No. NCS000247
legal authority and ordinances needed for inspection and enforcement
procedures.
(d) The implementation of inspection and monitoring programs for stormwater
structures, industrial activities and other areas of the stormwater
system . These programs will include provisions to assure compliance
through enforcement capabilities.
(e) The implementation of programs to reduce pollutants from construction
sites through site planning, education, training and inspection and
enforcement mechanisms.
The approved SWAMP along with all provisions and approved modifications of the
SWAMP are incorporated by reference and are enforceable parts of this permit.
(5) The City of Winston-Salem will implement monitoring efforts as outlined in the
Stormwater Program to prioritize areas of the program and to assess the
effectiveness of program components. These monitoring results will be used by
the City of Winston-Salem to modify the program components as necessary to
accomplish the intent of the Stormwater Program. Results of the monitoring
programs will be submitted to the Division according to the provisions of
Section C of this Part.
(6) Monitoring programs in the context of this permit are not limited only to
conventional monitoring in the form of sampling and analysis activities.
Assessment of program implementation, use of programs established by the
Stormwater Program, etc. are also a part of this process. Sampling activities
are required as part of the monitoring process in accordance with the
provisions outlined in the Stormwater Program.
(7) 180 Days prior to the expiration date of this permit (March 9, 2003) the City
of Winston-Salem will submit a permit renewal application. The renewal
application shall include a review of the Stormwater Program development and
implementation over the life of this permit. In addition, the review will
include the status of programs and a description of further program development
including the incorporation of NPDES Phase II requirements as defined by 40CFR
122.34, to be implemented over the future permitting time period.
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Permit No. NCS000247
SECTION C: STORMWATER PROGRAM REPORTING AND MONITORING REQUIREMENTS
The City of Winston-Salem's reporting and monitoring activities in support of this
permit will be sufficient to indicate progress in implementation, effectiveness and
results of the Stormwater Program and individual components of the program. The
Division may request additional reporting and monitoring information as necessary to
assess the progress and results of the City of Winston-Salem's Stormwater Program.
(1) The City of Winston-Salem's Stormwater Program will be reviewed and updated as
necessary, but at least on an annual basis. Implementation of the Stormwater
Program will include documentation of all program components that are being
undertaken including, but not limited to, monitoring and sampling, inspections,
maintenance activities, educational programs, implementation of BMPs and
enforcement procedures. Documentation will be kept on -file by the City of
Winston-Salem for a period of five years and made available to the Director or
his authorized representative immediately upon request.
(2) The Director may notify the City of Winston-Salem when the Stormwater Program
does not meet one or more of the requirements of the permit. Within 30 days of
such notice, the City of Winston-Salem will submit a time schedule to the
Director for modifying the Stormwater Program to meet minimum requirements.
The City of Winston-Salem will provide certification in writing (in accordance
with Part II, S:andard Conditions, Section B, #10) to the Director that the
changes have been made.
(3) The City of Winston-Salem will submit reporting and monitoring information on
an annual basis. This information will be submitted by August 31st of each
year and cover :he previous year's activities from July 1st to June 30th. The
City of Winston-Salem's reporting and monitoring program will include
appropriate information to accurately describe the progress, status and results
of the City's Stormwater Program and will include, but is not limited to, the
following components:
(a) The City of Winston-Salem will give a detailed description of the status
of implementation of the Stormwater Program. This will include
information on development and implementation of all components of the
Stormwater Program for the past year and schedules and plans for the
year following each report.
(b) The City of Winston-Salem will adequately describe and justify any
proposed changes to the Stormwater Program. This will include
descriptions and supporting information for the proposed changes and how
these changes will impact the Stormwater Program (results,
effectiveness, implementation schedule, etc.),
(c) The City of Winston-Salem will document any necessary changes to
programs or practices for assessment of management measures implemented
through the Stormwater Program. In addition, any changes in the cost
of, or funding for, the Stormwater Program will be documented.
(d) The City of Winston-Salem will include a summary of data accumulated as
part of the Stormwater Program throughout the year along with an
assessment of what the data indicates in light of the Stormwater
Program, The City of Winston-Salem will provide information on the
status of monitoring program development and, as appropriate, include
detailed information on the monitoring programs established.
(e) The City of Winston-Salem will provide information on the annual
expenditures and budget anticipated for the year following each report
along with an assessment of the continued financial support for the
overall Stormwater Program.
(f) The City of Winston-Salem will provide a summary of activities
undertaken as part of the Stormwater Program throughout the year. This
summary will include, but is not limited to, information on the
establishment of appropriate legal authorities, inspection, maintenance
and enforcement actions, continued inventory and review of the storm
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Permit No. NCS000247
sewer system, and results of education, training and illicit connections
programs
(g) The City of Winston-Salem will provide information concerning areas of
water quality improvement or degradation. Depending on the level of
implementation of the Stormwater Program, this information may be
submitted based on pilot studies, individual projects or on a watershed
or subwatershed basis.
(4) The Director may request reporting information
deemed necessary either for specific portions
Stormwater Program, or for the entire Program,
on a more frequent basis as
of the City of Winston-Salem's
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Permit No. NCS000247
PART II
STANDARD CONDITIONS FOR NPDES STORMWATER PERMITS
SECTION A. DEFINITIONS
1. Act or "the Act" or CWA
The Federal Water Pollution Control Act, also known as the Clean Water Act,
as amended, 33 USC 1251, et. seq.
2. Best Management Practices (BMPs)
Schedules of activities, prohibitions of practices, maintenance procedures,
and other management practices to prevent or reduce the pollution of waters of
the United States. BMPs also include treatment requirements, operation
procedures, and practices to control plant site runoff, spillage or leaks,
sludge or waste disposal, or drainage from raw material storage.
3. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products
with a single above ground storage container having a capacity of greater than
660 gallons or with multiple above ground storage containers having a total
storage capacity of greater than 1,320 gallons.
4. Calculation of Means
a. Arithmetic Mean: The arithmetic mean of any set of values is the summation of
the individual values divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of
the product of the individual values where N is equal to the number of
individual values. The geometric mean is equivalent to the antilog of the
arithmetic mean of the logarithms of the individual values. For purposes of
calculating the geometric mean, values of zero (0) shall be considered to be
one (1) .
C. Weighted by Flow Value: Weighted by flow value means the summation of each
concentration tames its respective flow divided by the summation of the
respective flows.
5. Calendar Day
The period from midnight of one day until midnight of the next day. However,
for purposes of this permit, any consecutive 24-hour period that reasonably
represents the calendar day may be used for sampling.
6. Coal Pile Runoff
The rainfall runoff from or through any coal storage pile.
7. DWO or Division
The Division of Water Quality, Department of Environment and Natural
Resources.
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Permit No. NCS000247
8. Director
The Director of the Division of Water Quality, the permit issuing authority.
9. EMC
The [forth Carolina Environmental Management Commission.
10 Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the
Clean Water Act.
11. Illicit Discharge
Any discharge to a separate storm sewer system (including municipal separate
storm sewers) that is not composed entirely of stormwater except discharges
pursuant to a NPDES permit and discharges from firefighting activities.
12. Landfill
A disposal facility or part of a disposal facility where waste is placed in or
on land and which is not a land treatment facility, a surface impoundment, an
injection well, a hazardous waste long-term storage facility or a surface
storage facility.
13, Larne or Medium Municipal Separate Storm Sewer System
All municipal separate storm sewers that are either:
a. Located in an incorporated place with a population of 100,000 or more as
determined by the Decennial Census by the Bureau of Census; or
b. Located in the counties with unincorporated urbanized populations of
100,000 or more, except municipal separate storm sewers that are located in
the incorporated places, townships or towns within such counties; or
c. Owned or operated by a municipality other than those described in paragraph
(a) or (b) and that are designated by the Director as part of the large or
medium separate storm sewer system.
14. Municipal ,Separate Storm Sewer Svstem(MS4)
A conveyance or system of conveyances (including roads with drainage systems,
municipal streets, catch basins, curbs, gutters, ditches, man-made channels
and storm drains):
a. owned or operated by a State, city, town, borough, county, parish,
district, association, or other public body (created by or pursuant to
State Law) having jurisdiction over disposal of sewage, industrial wastes,
stormwater, or other wastes, including special districts under State Law
such as sewer district, flood control district or drainage district, or
similar entity, or Indian Tribe or an authorized Indian tribal
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Permit No. NCS000247
organization, or a designated and approved management agency under section
208 of the CWA that discharges to waters of the United States;
b. designed or used for collecting or conveying stormwater
c. which is not a combined sewer; and
d. which is not part of a Publicly Owned Treatment Works (POTW) as defined at
40CFD 122.2.
e.
15. Outfall
A point source discharge as defined in this section as the point where the
source discharges to waters of the state.
16. Overburden
Any material of any nature, consolidated or unconsolidated, that overlies a
mineral deposit, excluding topsoil or similar naturally -occurring surface
materials that are not disturbed by mining operations.
17. Permittee
The owner or operator issued this permit.
18. Point Source Discharge
Any discernible, confined and discrete conveyance, including but specifically
not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete
fissure, container, rolling stock, or concentrated animal feeding operation
from which pollutants are or may be discharged•to waters of the state.
19. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded
by at least 72 hours in which no storm event measuring greater than 0.1 inches has
occurred. A single storm event may contain up to 10 consecutive hours of no
precipitation. For example, if it rains for 2 hours without producing any
collectable discharge, and then stops, a sample may be collected if a rain producing
a discharge begins again within the next 10 hours.
20. Runoff Coefficient
The fraction of total rainfall that is not infiltrated into or otherwise
retained by the soil, concrete, asphalt or other surface upon which it falls
that will appear at the conveyance as runoff.
21. Secondary Containment
Containment for the contents of the single largest tank within the containment
structure plus sufficient freeboard to allow for the 25-year, 24-hour storm
event.
22. Section 313 Water Priority Chemical
A chemical or chemical category which:
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Permit No. NCS000247
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) of 1986, also titled
the Emergency Planning and Community Right -to -Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA title
III, Section 313 reporting requirements; and
c. That meet at least one of the following criteria:
(1) Is listed in appendix D of 40 CFR part 122 on either Table II (organic
priority pollutants), Table III (certain metals, cyanides, and
phenols) or Table IV (certain toxic pollutants and hazardous
substances);
(2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of
the CWA at 40 CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water
quality criteria.
23. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as
solvents, detergents, and plastic pellets; finished materials such as metallic
products; raw materials used in food processing or production; hazardous
substances designated under section 101(14) of CERCLA; any chemical the
facility is required to report pursuant to section 313 of Title III of SARA;
fertilizers; pesticides; and waste products such as ashes, slag and sludge
that have the potential to be released with stormwater discharges.
24. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in
excess of reportable quantities under section 311 of the Clean Water Act (Ref:
40 CFR 110.10 and CFR 117.21) or section 102 of CERCLA (Ref: 40 CFR 302.4).
25. Storm Sewer System
Is a conveyance or system of conveyances which are designed or used to collect
or convey stormwater runoff that is not part of a combined sewer system or
treatment works. This can include, but is not limited to, streets, catch
basins, curbs, gutters, ditches, man-made channels or storm drains that convey
stormwater runoff.
26. Stormwater Runoff
The flow of water which results from precipitation and which occurs
.immediately following rainfall or as a result of snowmelt.
27. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying
stormwater and which is directly related to manufacturing, processing or raw
material storage areas at an industrial site. Facilities considered to be
engaged in "industrial activities" include those activities defined in 40 CFR
122.26(b)(14). The term does not include discharges from facilities or
activities excluded from the NPDES program.
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Permit No. NCS000247
28. Ten Year Design Storm
The precipitation event of a duration which will produce the maximum peak rate
of runoff for the watershed of interest resulting from a rainfall event of an
intensity expected to be equalled or exceeded, on the average, once in ten
years.
29. 'Total Flow
The flow corresponding to the time period over which the sample collection
occurs. The total flow calculated based on the size of the area draining to
the out£all, the amount of the built -upon surfaces within the drainage area,
and the total amount of rainfall occurring during the sampling period.
30. Toxic Pollutant
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
31. Types of Samples
a. Grab samples are individual samples collected instantaneously.
b. Composite Sample: a composite sample shall mean:
(1) A flow -weighted composite sample, which is a mixture of aliquots
collected at a constant time interval, where the volume of each
aliquot is proportional to the flow rate of the discharge at the time
the sample is collected; or '
(2) A time -weighted composite sample, which is a mixture of equal volume
aliquots collected at a constant interval of time.
A composite sample can be obtained from the collection of a series of
grab samples, taken at intervals of no greater than 20 minutes for the
entire storm event or the first three hours of the storm event. The
grab sample to be composited must be of no less than 100 milliliters.
32. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication,
vehicle cleaning operations, or airport deicing operations.
33. Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being
transported by water, air, gravity, or ice from its site of origin which can
be seen with the unaided eye.
34. waste Pile
Any noncontainerized accumulation of solid, nonflowing waste that is used for
treatment or storage.
35. 25-year, 24 hour storm event
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Permit No. NCS000247
The maximum 24-hour precipitation event expected to be equalled or exceeded,
on the average, once in 2S years.
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Permit No. NCS000247
SECTION S. GENERAL CONDITIONS
1. Duty to Comply
The permittee must comply with all conditions of this individual permit. Any
permit noncompliance constitutes a violation of the Clean Water Act and is
grounds for enforcement action; for permit termination, revocation and
reissuance, or modification; or denial of a permit upon renewal application.
a. The permittee shall comply with standards or prohibitions established
under section 307(a) of the Clean Water Act for toxic pollutants within
the time provided in the regulations that establish these standards or
prohibitions, even if the permit has not yet been modified to
incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit
condition is subject to a civil penalty not to exceed $25,000 per day
for each violation. Any person who negligently violates any permit
condition is subject to criminal penalties of $2,500 to $25,000 per day
of violation, or imprisonment for not more than 1 year, or both. Any
person who knowingly violates permit conditions is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for
not more than 3 years, or both. Also, any person who violates a permit
condition may be assessed an administrative penalty not to exceed
$10,000 per violation with the maximum amount not to exceed $125,000.
[Ref: Section 309 of the Federal Act 33 USC 1319 and 40 CFR 122.41(a).]
C. Under state law, a daily civil penalty of not more than ten thousand
dollars ($10,000) per violation may be assessed against any person who
violates or fails to act in accordance with the terms, conditions, or
requirements of a permit. [Ref: North Carolina General Statutes 143-
215.6A]
d. Any person may be assessed an administrative penalty by the Director for
violating section 301, 302, 306, 307, 308, 318, or 405 of the Act, or
any permit condition or limitation implementing any of such sections in
a permit issued under section 402 of the Act. Administrative penalties
for Class I violations are not to exceed $10,000 per violation, with the
maximum amount of any Class I penalty assessed not to exceed $25,000.
Penalties for Class II violations are not to exceed $10,000 per day for
each day during which the violation continues, with the maximum amount
of any Class II penalty not to exceed $125,000.
2. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any
discharge in violation of this permit which has a reasonable likelihood of
adversely affecting human health or the environment.
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Permit No. NCS000247
3
4.
5
CN
7
8.
Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, C.3.),
nothing in this permit shall be construed to relieve the permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS
143-215.3, 143-215.6A, 143-215.6B, 143-215.6C or Section 309 of the Federal
Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential
damages, such as fish kills, even though the responsibility for effective
compliance may be temporarily suspended.
Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any
legal action or relieve the permittee from any responsibilities, liabilities,
or penalties to which the permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321. Furthermore,
the permittee is responsible for consequential damages, such as fish kills,
even though the responsibility for effective compliance may be temporarily
suspended.
Property Rights
The issuance of this permit does not convey any property rights in either real
or personal property, or any exclusive privileges, nor does it authorize any
injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations.
Severability
The provisions of this permit are severable, and if any provision of this
permit, or the application of any provision of this permit to any
circumstances, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit, shall not be affected
thereby.
Duty —to Provide_ Information
The permittee shall furnish to the Director, within a reasonable time, any
information which the Director may request to determine whether cause exists
for modifying, revoking and reissuing, or terminating this permit or to
determine compliance with this permit. The permittee shall also furnish to
the Director upon request, copies of records required to be kept by this
permit.
Duty to Reapply
if the permittee wishes to continue an activity regulated by this permit after
the expiration date of this permit, the permittee must apply for renewal of
the permit.
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Permit No. NCS000247
9. Expiration of Permit
The permittee is not authorized to discharge after the expiration date. In
order to receive automatic authorization to discharge beyond the expiration
date, the permittee shall submit such information, forms and fees as are
required by the agency authorized to issue permits no later than 180 days
prior to the expiration date. Any permitte that has not requested renewal at
least 180 days prior to expiration, or any discharge that does not have a
permit after the expiration and has not requested renewal at least 180 days
prior to expiration, will be subject to enforcement procedures as provided in
NCGS 143-215.6 and 33 USC 1251 et seq.
10, Signatory Requirements
All applications, reports, or information submitted to the Director shall be
signed and certified.
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of
this Section, a responsible corporate officer means: (a) a president,
secretary, treasurer or vice president of the corporation in charge of a
principal business function, or any other person who performs similar policy
or decision making functions for the corporation, or (b) the manager of one or
more manufacturing production or operating facilities employing more than 250
persons or having gross annual sales or expenditures exceeding 25 million (in
second quarter 1980 dollars), if authority to sign documents has been assigned
or delegated to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the
proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a
principal executive officer or ranking elected official.
b. All reports required by the permit and other information requested by the
Director shall be signed by a person described above or by a duly authorized
representative of that person. A person is a duly authorized representative
only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having
responsibility for the overall operation of the regulated facility or
activity, such as the position of plant manager, operator of a well or well
field, superintendent, a position of equivalent responsibility, or an
individual or position having overall responsibility for environmental matters
for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
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Permit No. NCS000247
(3) The written authorization is submitted to the Director.
c. Certification. Any person signing a document under paragraphs a. or b. of
this section shall make the following 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."
11. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause.
The filing of a request by the permittee for a permit modification, revocation
and reissuance, or termination, or a notification of planned changes or
anticipated noncompliance does not stay any permit condition.
12. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the Director from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the
permit as allowed by the laws, rules, and regulations contained in Title 40,
Code of Federal Regulations, Parts 122 and 123; Title 15A of the North
Carolina Administrative Code, Subchapter 2H .0100; and North Carolina General
Statute 143-215.1 et. al.
13. ReQuiring an Individual Permit
The Director may require, through written notification, any entity covered
under this permit to apply for their own independent NPDES permit. The
Director's notification will establish requirements for permit application and
coverage.
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Permit No. NCS000247
SECTION C. OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities
and systems of treatment and control (and.related appurtenances) which are
installed or used by the permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This
provision requires the operation of back-up or auxiliary facilities or similar
systems which are installed by a permittee only when the operation is
necessary to achieve compliance with the conditions of the permit.
2. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it
would have been necessary to halt or reduce the permitted activity in order
to maintain compliance with the condition of this permit.
3. Bypassing of Stormwater Control. Facilities
a. Definitions
(1) "Bypass" means the known diversion of stormwater from any portion of a
stormwater control facility including the collection system, which is not a
designed or established or operating mode for the facility.
(2) "Severe property damage" means substantial physical damage to property,
damage to the control facilities which causes them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does
not mean economic loss caused by delays in production.
b. Bypass not exceeding limitations.
The permittee may allow any bypass to occur which does not cause effluent
limitations to be exceeded, but only if it also is for essential maintenance
to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs c. and d. of this section.
c. Notice
(1) Anticipated bypass. If the permittee knows in advance of the need for a
bypass, it shall submit prior notice, if possible at least ten days before the
date of the bypass; including an evaluation of the anticipated quality and
affect of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice of an unanticipated
bypass as required in Part II, E. 5. of this permit. (24-hour notice).
d. Prohibition of Bypass
(1) Bypass is prohibited and the Director may take enforcement action against a
permittee for bypass, unless:
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Permit No. NCS000247
fa) Bypass was unavoidable to prevent loss of life, personal injury or
severe property damage;
(b) There were no feasible alternatives to the bypass, such as the use of
auxiliary control facilities, retention of stormwater or maintenance
during normal periods of equipment downtime or dry weather. This
condition is not satisfied if adequate backup controls should have been
installed in the exercise of reasonable engineering judgment to prevent
a bypass which occurred during normal periods of equipment downtime or
preventive maintenance; and
(c) The permittee submitted notices as required under Paragraph c. of this
section.
(2) The Director may approve an anticipated bypass, after considering its adverse
effects, if the Director determines that it will meet the three conditions
listed above in Paragraph d. (1) of this section.
4. Upsets
a. Definition.
"Upset " means an exceptional incident in which there is unintentional and
temporary noncompliance with technology based permit effluent limitations
because of factors beyond the reasonable control of the permittee. An upset
does not include noncompliance to the extent caused by operational error,
improperly designed treatment or control facilities, inadequate treatment or
control facilities, lack of preventive maintenance, or careless or improper
operation.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for
noncompliance with technology based permit effluent limitations if the
requirements of paragraph c. of this condition are met. No determination made
during administrative review of claims that noncompliance was caused by upset,
and before an action for noncompliance, is final administrative action subject
to judicial review.
C. Conditions necessary for a demonstration of upset.
A permittee who wishes to establish the affirmative defense of upset shall
demonstrate, through properly signed, contemporaneous operating logs, or other
relevant evidence that:
(1) An upset occurred and that the permittee can identify the cause(s) of the
upset;
(2) The permitted facility was at the time being properly operated; and
(3) The permittee submitted notice of the upset as required in Part II, E. 5. (b)
(B) of this permit.
(4) The permittee complied with any remedial measures required under Part II, A.
2. of this permit.
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Permit No. NCS000247
d. Burden of proof.
in any enforcement proceeding the permittee seeking to establish the
occurrence of an upset has the burden of proof.
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Permit No. NCS000247
SECTION D. MONITORING AND RECORDS
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be
characteristic of the volume and nature of the permitted discharge. Samples
shall be taken on a day and time that is characteristic of the discharge. All
samples shall be taken at the monitoring points specified in the SWQMP or
suitable representative sites and, unless otherwise specified, before the
discharge joins or is diluted by any waste stream, body of water, or
substance. The Director may request information justifying changes to
sampling locations and sampling methods at any time. At a minimum,
.information on such changes shall be reported in the permittee's annual
report. The Director may require that certain changes in the sampling program
be submitted for approval prior to implementation of the changes.
2. Reporting
Duplicate signed copies of all reports required herein, shall be submitted to
the following address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent
with accepted scientific practices shall be selected and used to ensure the
accuracy and reliability of measurements of the volume of monitored
discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC
regulations published pursuant to NCGS 143-215.63 et. seq, the Water and Air
Quality Reporting Acts, and to regulations published pursuant to Section
304(h), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended,
and Regulation 40 CFR 136. Reporting of analytical results as "too numerous
to count" (TNTC) will not be acceptable and may constutute a violation.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or
knowingly renders inaccurate, any monitoring device or method required to be
maintained under this permit shall, upon conviction, be punished by a fine of
not more than $10,000 per violation, or by imprisonment for not more than two
years per violation, or by both. If a conviction of a person is for a
violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more that $20,000 per day of violation,
or by imprisonment of not more than 4 years, or both.
Page 20

Permit No. NCS000247
6. Records Retention
The permittee shall retain records of all monitoring information, including
all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, copies of all reports
required by this permit, for a period of at least 5 years from the date of
the sample, measurement, report or application. This period may be extended
by request of the Director at any time.
7. Recording Results
For each measurement, sample, inspection or maintenance activity performed or
taken pursuant to the requirements of this permit, the permittee shall record
the following information:
a. The date, exact place, and time of sampling, measurements, inspection or
maintenance activity;
b. The individual(s) who performed the sampling, measurements, inspection or
maintenance activity;
C. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The permittee shall allow the Director, or an authorized representative
(including an authorized contractor acting as a representative of the
Director), upon the presentation of credentials and other documents as may be
required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is
located or conducted, or where records must be kept under the conditions of
this permit;
b. Have access to and copy, at reasonable times, any records that must be kept
under the conditions of this permit;
C. Inspect at reasonable times any facilities, equipment (including monitoring
and control equipment), practices „ or operations regulated or required under
this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit
compliance or as otherwise authorized by the Clean Water Act, any substances
or parameters at any location.
SECTION E. REPORTING REQUIREMENTS
1. Planned Changes
Page 21

Permit No. NCS000247
The permittee shall give notice to the Director of any planned modifications
to the Stormwater Program or SWQMP, Notice of any changes is required at
least through the annual report as specified in Part I Section C of this
permit. Notice shall be given as soon as possible when:
a. The modification represents a change in the form of deleting a provision of
the approved Stormwater Program; or
b. The modification could significantly change the timeframe for implementation
of parts of the program or negatively influence the effectiveness of the
approved program.
2. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes
in the permitted facility or activity which may result in noncompliance with
the permit requirements.
3. Transfers
This permit is not transferable to any person except after notice to and
approval by the Director. The Director may require modification or revocation
and reissuance of the permit to change the name and incorporate such other
requirements as may be necessary under the Clean Water Act.
4. Monitorinq Reports
Monitoring results shall be reported at the intervals specified elsewhere in
this permit.
5. 'Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional
office any noncompliance which may endanger health or the environment. Any
information shall be provided orally within 24 hours from the time the
permittee became aware of the circumstances. A written submission shall also
be provided within 5 days of the time the permittee becomes aware of the
circumstances.
The written submission shall contain a description of the noncompliance, and
its causes; the period of noncompliance, including exact dates and times, and
if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance.
b. The following shall be included as information which must be reported within
24 hours under this paragraph.
(A) Any unanticipated bypass which exceeds any effluent limitation in the permit,
(R) Any upset which exceeds any effluent limitation in the permit.
(C) Violation of a maximum daily discharge limitation for any of the pollutants
listed by the Director in the permit to be reported within 24 hours.
Page 22

Permit No. NCS000247
C. The Director may waive the written report on a case -by --case basis for reports
under paragraph b. above of this condition if the oral report has been
received within 24 hours.
6. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under
Part II. E. 4 and 5. of this permit at the time monitoring reports are
submitted. The reports shall contain the information listed in Part II. E. 5.
of this permit.
7. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts
or submitted incorrect information in a permit application or in any report to
the Director, it shall promptly submit such facts or information.
8. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or
Section 308 of the Federal Act, 33 USC 1318, all reports prepared in
accordance with the terms shall be available for public inspection at the
offices of the Division of Environmental Management. As required by the Act,
effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal
penalties as provided for in NCGS 143-215.6E or in Section 309 of the Federal
Act.
9. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false
statement, representation, or certification in any record or other document
submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be
punished by a fine of not more than $10,000 per violation, or by imprisonment
for not more than two years per violation, or by both.
Page 23

Permit No. NCS000247
Part III
OTHER INFORMATION
A. Limitations Reopener
k" This permit shall be modified or alternatively, revoked and reissued, to
comply with any applicable effluent guideline or water quality standard issued
or approved under Sections 302(b) (2) (c), and (d), 304(b) (2) and 307(a) of
the Clean Water Act, if the effluent guideline or water quality standard so
issued or approved:
1. contains different conditions or is otherwise more stringent than any effluent
limitation in the permit; or
2. controls any pollutant not limited in the permit.
The permit as modified or reissued under this paragraph shall also contain any
other requirements in the Act then applicable.
PART IV
ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
A. The permittee must pay the administering and compliance monitoring fee
associated with this permit within 30 (thirty) days after being billed by the
Division. Failure to pay the fee in a timely manner in accordance with 15A
NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the
permit.
Page 24

I o
n
I
�
t�
a
a.
4 r

Grounds Maintenance
James Mitchell I ' Landscaping I
Dir Veg Mgt ICI I GarbageCollectfon
Urban Forestry
14
Johnnie Taylor Yard Waste and Bulky Item
Sanitation
Water and Sewer
Recycling
Oavo Saunders I Solid Waste Gisposa!
Utilities
Design Operations
Cemetaries
14
Russ Byrd Financial/Records
Engineering Information
Building Inspections
Greg Turner Field Inspections
Assistant City Manager7Public Works
f-G'hadia Nortonning Inspections
nspections
Traffic Operations
Erosion Control
I j Stan s WSTA I
TransportatiortO on
Streets Maintenance
Ruben Prestwood ParkingfTrafrc Support
Streets
Public Works
Communications
Development Plan Review
Keith Ruff I I . Water Quality Management Program
Stormwater -f--I
Public Education/Involvement

P:1127968 Winston Salem CMOM SSO Asses smentllnformation
Gathering\Client Provided\SSO POLICY.WPD
City/County Utility
Commission Sanitary
Sewer Overflow
Response Policy and
Procedures
Prepare! June 30, 1999
Revised September 19, 2000
Revised November 17, 2002
ReviscyJ October 27, 2003
Revisal March 4. 2005
Prepared for
City oi'Winston-Salem, Nortb Carolina
by
Richard McMillan, P.E, and David K. Saunders, P.E.

P:1127968 Winston Salem CMOM SSO Asses sme nt\I n format ion GatheringUient ProvideMSO
POLICY. WPD
Table of Contents
Purpose........................................................................................................................... I
Policy- City/County Utility Commission Sanitary Sewer Overflow Response Policy and Procedures .......... 2
Sanitary Sewer Ovcrtlow,/Spill Contact Fames and Numbers.......................................................................4
EquipmentList.............................................................................................................................................6
Contractors and Suppliers............................................................................................................................7
ResponseProcedures....................................................................................................................................8
Outf'al ls:.................................................................................................................................................8
Streetor Right-of-Ways:.........................................................................................................................8
Yardor Landscaped Area: ........................................................................................... ..... — ........ — ... 8
PutnpStation:..........................................................................................................................................9
Pondor Lake:..........................................................................................................................................9
Stream/Creek:......................................................................................................................................10
Inside Business or Residence: .................................................... ...... ...................... ............................ 10
Sanitary Sewer Overflow/Bypass Form (attached)........................................................................................
Overflow/Bypass Form Computation Page, and Location Map.............................................................
Comment [COMMENT21: phis page
l,intcn[ionatla id) blank

Purpose
0n'/Cotrnry Utilirn Co+nmission Sanitury Sewer Otv flow Response Polic'v urrd
Procedurres
The purpose of this document is to protect the citizens of Winston-Salem and
Forsyth County, the customers of the City/County Utility Commission and the
environment by establishing written procedures for responding; to and remediating
sanitary sewer overflows and spills within the system operated by the City/County
Utility Commission. The procedures in this report apply to all Utility Commission
employees that may deal with sanitary sewer overflow or spills. These procedures
will be reviewed and updated as necessary to remain in compliance with all local,
state and federal requirements.
(} means used everyday in wastewater. Other number is total available at C&M
Page I

CirvlCounnY Uriliry Commission Sanirary Svuver Overflow Response Policv arrd
Procedures
Policy- City/County Utility Commission Sanitary Sewer
Overflow Response Policy and Procedures
Sanitary Sewer overilowsrspills endanger the environment and potentially the
health of any citizens, customers or employees that come in contact with the
overflow. North Carolina Department of Environment and Natural Resources
regulations require significant penalties for noncompliance with the
Compliance and Enforcement Policy for Water Quality. The procedures
described in this policy were designed to protect the environment, citizens,
customers, and employees from an overflow/spill event. These procedures
apply to all City of Winston-Salem employees.
Collection System: Work schedules shall be the responsibility of the
Collection System Supervisor and are designed so that at all times there is an
assigned crew leader/ crew coordinator either on duty or on call to respond to
overflow/spill events. Upon discovery of an overflow/spill the assigned crew
leader or crew coordinator shall make an initial response within two hours of
notification of the event. Upon arrival the crew leader/coordinator shall make
an immediate assessment to determine if an overflowlspill has taken place, if
an overflow event has taken place or is in progress the crew
leader/coordinator shall attempt to eliminate the source of the overflow and
notify the Collection System Supervisor or his designee.
The Collection System Supervisor, or his designee, will respond to the
overflow location without delay. Upon arrival the Supervisor will make an
assessment as to what remediation and clean up procedures are required and if
additional personnel will be required to complete the remediation and clean
up of the event. ( Note: More detailed cleanup procedures are included in
later sections of this policy.)
3. Lift Stations: Work Schedules shall be the responsibility of the Assistant Plant
Supervisor (Lift Stations) and are designed so that at all times there is
assigned lift station mechanics either on duty or on call to respond to
overflow/spill events at lift stations. Upon discovery of an overflow/spill, the
assigned lift station mechanic shall make a initial response within two hours
of notification of the event, Upon arrival, the mechanic shall make an
immediate assessment to determine if an overtlw/spill has taken place. If an
overflow evetn has taken place or is in progress, the mechanic shall attempt to
eliminate the source of the overflow and notify the Assistant Plant Supervisor
(Lift Stations) or their designee.
(} means used everyday in wastewater. Other number is total available at C&M
Page 2

Cin-/Coautty Ufility Conuuission Sanilmy Server Overylow Response Policv and
Procedures
3, Continuer!
The Assistant Plant Supervisor (Lift Stations) or their designee, will respond
to the overflow location without delay. Upon arrival, the Supervisor will make an
assessment as to what rcrnediation and clean up procedures are required and if
additional personnel will be required to complete the remediation and clean up of
the event. Crews from Construction and Maintenance may be called to assist in
cleanup and remediation. (Note: More detailed cleanup procedures are included in
later sections ofthis policy.)
4. It shall also be the responsibility of the Collection System/ Assistant Plant
Supervisor to determine the NCDENR reporting requirements for the
overflow. The reporting requirements shall be as outlined below:
a. All overflows and spills. Regardless of size or location shall be logged
into the appropriate Sanitary Sewer Overflow Log Book by the
Collection System Supervisor or Assistant Plant Supervisor.
b. Any spill, regardless of volume, that reaches waters of the state shall be
reported to North Carolina Department of Environment (NCDENR,
DWQ). Please note that conveyances such as drainage ditches and
storm sewers are considered to be waters of the state.
c. Any spill that exceeds 1,000 gallons shall be reported to the NCDENR,
DWQ.
d. Any spill event that requires reporting to the state shall be called into the
regional office as soon as possible, but no later than 24 hours after the
discovery of the spill. The appropriate notification numbers are provided
in the following section entitled Sanitary Sewer Overflow/Spill Contact
Names and Numbers.
In addition the appropriate written report and spill response evaluation
form must be completed and submitted to the state within five (5)
days after discovery of the overflow/spill event. (Sample form is
attached).
e. Press releases are due within 48 hours on all spills over 1,000 gallons,
and public notice for spills over 15,000 gallons.
(} ineans used everyday in wastewater. Other number is total available. at C&M
Page 3

Cifv/Coarnty Utility Commission Smailun, Sewer Ove{flow Rcsponse Policy and
Procedures
Sanitary Sewer Overflow/Spill Contact Names and Numbers
Regional Office, NCDENR NC Division of Emergency Management l
Rose Pruitt 800-858-0368 (After regular hours, and
771-4000 Weekends and Holidays).
Collection Svstctns
(Primary Contacts)
SSO Pager
Waste Water Lift Stations
779-5037
(Primary Contacts)
Carried by On Call person
Collection System
Lift Station Supervisor
Supervisor
Lee Kimbrell
Michael Alexander
Office 765-0130
Office 650-7650 ext 1036
Cell 399-5805
Cell 462-1763
Pager 208-0370
Pager 779-4941
Kim Duncan
Office 650-7650 cxt 1037
Mobile [phone]
Wastewater Treatment Superintendent
Wastewater Collection
Supervisor Stan Webb Office 765-0130
Home 945-5620
James 1laaTis
Office 650-7650 ext 1006
Cell 462-1761
Horne 768-0393
{) means used everyday in wastewater. Other number is total available at C&M
Page 4

Utilities C&M Engineer
Paul Williams
Office 650-7650 ext 1004
Cell 399-5070
Utilities Superintendent
David Saunders
Office 727-8418
Cell 413-0545
Home 924-4988
CirviCounry Utility Commission Sanirwy Sewc'r' Ove)flow Response Policy and
Proce d wvs
Additional Contacts
Utilities Plains
Ron Hargrove
Office 727-8418
Cell 399-6834
Home 766 9778
{) tneans used everyday in wastewater. Other number is total available at C&lvl
Page 5

Equipment List
Number
2
l
3
3
6
2
8 (5)
2
2
11 (5)
1
2(i)
I
I
1
5
4
10 (4)
5
CirvICOunrl' Urifiry Commission Sunilar.v Server 01erjlow Rrsponse Policy and
Procedures
Equipment Description
Sewer Jets 680, 681,671
Combination Sewer Jct-Vac
Trailer Mount Vac
Trailer Mount Jets
Cargo Vans
Connection Cameras
Easement Machine
CCTV Trucks
Dump Trucks
Crane Truck
Mowing Tractors
Contract Mowing Tractors
Rubber -tire Backhoes
Small Track Excavator (volvo)
Track Excavators
Contract Track excavator
"Track Loader
Rubber Tire Loader
Gasoline Generators
Chainsaws
Air Compressors
Small/Medium Pumps (air and gas)
Location
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Vegetation Management
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Ronnie's Trucking
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
Utilities C&M, MLK Drive
O means used everyday in wastewater, Other number is total available at C&M
Page 6

Citv/County Utility Commission Sunifun- Scvver Ore{ lovv Response Policy mart
Proeccl fires
Pumps - 700 GPM (diesel) Elledbe W WTP
Sell=Priming Diesel 1,500 GPM Utilities C&M, MLK Drive
(} means used everyday in wastewater. Other number is total available at C&lvl
Page 7

Cilv/Coarnty U101Y Commission Sanilati, Sewer Ovetjlow Response Poliev and
Procedures
Contractors, and Suppliers
Contractor
Ramey, Inc.
Ronnie's Trucking (Misc. Grading)
Baker Construction Kcmersville, NC
Transou's Forsyth Septic Service
Forsyth Rooter
Four Season's Environmental, Inc.
(Hazardous Materials, Oils, etc)
Shamrock Environmental Corp.
Supplier
Adam's Water and Sewer Supply
Hertz Rental
Prime Equipment
Contact
Jim Armentrout or Larry Feimster
9224000 Office 922-4000
924-9166 Home 922-1668
Phone No. 744-1330
John Baker
Office 996-5039
Home 993-2967
Phone No. 765-1 161
Phone No. 768-8494
Phone No. 273-2718
Phone No. 723 9889
Contact
Phone No, 924-0266
Phone No. 788-8640
Phone No, 661 -1211
O means used everyday in wastewater. Other nwnhcr is total available at C CM
Page 8

Cilv/Counly Utility Commission Sunirur7, Sewcr Orc>flmv Rosponse Policv and
Procc�rhu-cs
O means used everyday in wastewater. Other number is total available at C&M
Page 9

City/Coanly Utififv Commission Sanirary Setrer Ovefflow Response Policv rend
Procedio-es
Response Procedures
4utfalls:
I . Remove blockage in sewer main and wash [Hain thoroughly.
2, Contain spill with straw bales or other means.
3. Pump excess sewer back into sewer system.
4. Clean area of debris, paper, and other material.
5. Spread lime over the spill area and apply straw.
Street or Right -of -Way:
1. Remove blockage in sewer main and wash main thoroughly.
2, Contain spill with straw bales, berms, or other means.
3. Pump any excess back into sewer system.
4. Clean area of debris, paper, and other material.
5. Wash area thoroughly with water. If grease is present on the road, use a
pressure washer to remove grease from the road's surface.
Yard or Landscaped Area:
1. Rentove blockage in sewer main and wash main thoroughly.
2. Contain spill if possible with straw bales or other means. Tape off area with
yellow caution tape.
3. Pump excess sewer back into sewer system.
4. Clean area of debris, paper, and other material.
5. Spread lime over the spill area and apply straw and keep tape in place for a
minimum of 24 hours. After this period, remove tape.
O means used everyday in wastewater. Other number is total available at Clitvl
Page 10

0[Y1(.'0tn7tV Utility Comnrissiwr Sanilarl, Sewer Overflow Response Policv and
Procedures
Pump Station:
1. Correct the probiem at the pumping station and start pumps.
2. Contain spill with straw bales or other means.
3. Pump contained overflow back into the collection system or use vac truck to
collect spill.
4. Clean up area of debris, paper, ctc.
5. Spread lime over the affected area and reseed areas that have been washed of'
vegetation, and apply straw,
Pond or Lake:
1. Remove blockage in sewer main and wash main thoroughly.
2. Pump any excess standing sewer back into the system,
3. Skim pond or lake in affected area to remove debris, paper, and other material
from water's surface.
4. Spread lime over the ground spill area and apply straw, Do not allow any lime
to come in contact with surface waters. DO NOT place any chlorine tablets in
surface waters.
Stream/Creek:
I . Remove blockage in sewer main and wash main thoroughly.
2. Contain spill with straw bales or other means, if possible.
3. Pump excess sewer back into sewer system.
4. Clean area ordebris, paper, and other materials from waters, creek banks,
and/or ground. Wash the creek banks, if needed and non -erodible (rip -rap),
with water,
5. Spread lime over the ground spill area and apply straw. Do not allow any lime
to conic into contact with the surface waters. DO NOT place any chlorine
[) means used everyday in wastewater. Other number is total available at C&M
Page l l

Cirv/Corurn, Ulililt, Conmtission Sanirar v Smer Overjlow Respwrse Polic,v and
Procedures
tablets in surface waters.
Inside Business or Residence:
1. Remove blockage in sewer main and wash thoroughly.
2. Pump or vacuum any excess sewer back into sewer system.
3. Offer assistance with cleanup.
{) means used everyday in wastewater. Other number is total available at C&M
Page 12