NCS000547_Roxboro 2019 Annual Report_20191028

NPDES Phase II Stormwater
Annual Report
City of Roxboro

Fiscal Year 2018

Prepared by:
Josh Johnson, P.E.

And

Phil Ross
Stormwater Program
Coordinator

alley, williams, carmen & king, inc.
engineers and architects
740 chapel hill road - post office box 1179
burlington, north carolina 27216-1179
Phone: [phone]
Fax: [phone]

City of Roxboro Stormwater Annual Report
2018
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Report Outline
• Introduction
• NPDES Phase II.
o Minimum Control Measures.
 Public Education and Outreach.
 Public Involvement and Participation.
 Illicit Discharge Detection and Elimination.
 Construction Site Runoff Controls.
 Post Construction Stormwater Management.
 Pollution Prevention and Good Housekeeping.
• Impaired Waters and TMDL Waters.
o Listing of Impaired Waters
 Impairment Type.
 Timeline for Improvements.
 Current Status.
• Falls Lake Rules and Report.
• Stormwater Funding.
• Future Issues.
• Program Contacts.
City of Roxboro Stormwater Annual Report
2018
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Introduction

On July 1, 2005, The North Carolina Division of Water Quality (DWQ) in the Department of
Environmental Quality (DEQ formerly DENR) began issuing Phase II stormwater permits to municipalities
in North Carolina under the National Pollutant Discharge Elimination System Program (NPDES). At the
time, the NPDES Phase II Program was the latest stormwater program stemming from the Federal Clean
Water Act of 1972. Prior to the Phase II program, EPA and NC DEQ had issued NPDES Phase I Stormwater
Permits to Cities larger than 100,000 persons. In North Carolina these cities were Raleigh, Charlotte,
Fayetteville, Durham, Greensboro, and Winston Salem. The Phase II Program included distribution of
Phase II permits to municipalities less than 100,000 residents and began with municipalities within
Municipal Spheres of Influence (MSI) that were greater than 50,000 citizens.

Since 2006, Additional Communities have been designated as Phase II Communities due to size,
population density, and potential water quality impacts. The City of Roxboro was designated in 2010
because of a combination of population density and the Falls Lake Nutrient Strategy.
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2018
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The Phase II stormwater program was created with the intention of improving the quality of the nation’s
waterways by reducing the quantity of pollutants that stormwater transports into stormwater systems
and discharges to surface water bodies. The permit require permittees at a minimum to develop,
implement, and enforce a stormwater program designed to reduce the discharge of pollutants from the
municipal separate storm sewer system (MS4) to the maximum extent practicable. The stormwater
program is composed of the following six management measures:
1. Public Education and Outreach
2. Public Involvement and Participation
3. Illicit Discharge Detection and Elimination
4. Construction Site Runoff Controls
5. Post-Construction Site Runoff Controls
6. Pollution Prevention and Good Housekeeping for Municipal
Operations
Each of these measures consists of required Best Management Practices (BMPs), measurable goals for
each BMP and an implementation schedule for the 5 year permit cycle. Additionally, the City of Roxboro
has a Comprehensive Stormwater Management Program and completes annual reporting about the
NPDES Phase II Program. Because the NPDES Program concentrates on water quality it has limited
provisions concerning water quantity and flooding controls.
The City’s permit was officially issued in late 2011 and a copy of the permit is available either through
Josh Johnson, P.E. or through NC Division of Energy, Mineral and Land Resources (NC DEMLR – which as
of fall of 2013 now houses Stormwater Permitting).
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2018
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This Report is intended to complete the Annual Report specifying the City’s progression in implementing
the NPDES Permit and Comprehensive Stormwater Management Plan. It is also intended to give readers
a comprehensive idea of the City’s full Stormwater Program and provide reporting information for the
implementation of the Falls Lake Rules.
NPDES Phase II Minimum Control Measures
Each of the 6 Minimum Control Measures (MCM’s) has a set of best management practices (BMP’s) that
are intended to foster compliance with both the City’s Permit and CSWMP. These specific BMP’s can be
found in both the Permit and the CSWMP but highlights and specific actions will be noted in the report.
Public Education and Outreach
The City operates a Public Education and Outreach program that is designed to educate the general
public about the need to improve water quality in stormwater. The general objectives are to distribute
education materials to the community and/or to conduct equivalent outreach activities about the
impacts of storm water discharges on surface waters and the steps the public can take to reduce
pollutants in stormwater runoff. These objectives have been further refined to target residents, school
children, local businesses (specifically gas station owners and landscaping companies) and industry
because these groups have the most impact on stormwater pollution prevention.
The education program targets total suspended solids (TSS and sediment) and nutrient loading because
turbidity, sedimentation, and nutrients are the pollutants of concern in downstream waters.
The City has stormwater handouts on display at the Roxboro City Hall. The City on its website also
maintains a Stormwater Link: http://www.cityofroxboro.com/government/public-services/engineering-
services/stormwater-administration which has information on the stormwater ordinance.
Roxboro also partners with the Clean Water Education Partnership (CWEP), an education and outreach
organization hosted by the Triangle J Council of Governments (TJCOG). CWEP is a cooperative group
that is funded by over 37 communities in North Carolina. It was created in 2001 to provide education
and outreach for MS4 systems. CWEP has a large Mass Media Campaign that includes an educational
website, TV, Radio and Social Media campaigns. Through this resource CWEP is able to bring
stormwater education to a large population in the City of Roxboro and surrounding areas. In 2018 CWEP
hired its first AmeriCorps service member to conduct direct environmental education and outreach with
children and adults in CWEP communities this program was very successful and will continue.
The CWEP Coordinator is Jen Schmitz and you can find information about CWEP and their programs at
http://www.nccleanwater.org/. Jen can be reached at [e-mail] or at [phone].
For additional information about stormwater education the CWEP website has the most up to date
information available at http://www.nccleanwater.org/.

City of Roxboro Stormwater Annual Report
2018
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Public Participation and Involvement
The City has a responsibility to solicit and consider public opinion on all matters, including stormwater
management. Many times this involvement is lacking but the City is often times required to continue to
solicit public involvement. The City of Roxboro is currently in this situation. The City originally involved
the public with a public hearing in 2010 and has attempted to create a stormwater committee but has
not found a receptive audience. The City has been receptive to any questions from citizens, maintains a
helpline (City Hall at [phone] and has worked with CWEP but continues to struggle to establish
effective Public Participation and Involvement. The City did not hold a Stormwater Public Meeting in

CWEP Digital Media Impression Impact on Roxboro
and surrounding communities
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2018
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calendar year of 2018 but will hold one in the future as needed. This public meeting will seek input on
the stormwater program and will provide both input to the City as well as education to the citizens.
Illicit Discharge Detection and Elimination
The City of Roxboro has a full Illicit Discharge Detection and Elimination (IDDE) Program. The IDDE
Program is intended to reduce discharges to the stormwater system that are not entirely composed of
stormwater. There are a few permitted discharges and firefighting related discharges that are allowed.
An illicit discharge is typically dirt, soap, pet waste, litter, oil, fertilizer, pesticides, or raw sewage and
often times comes from “generating sites.” Generating sites are points of pollution that continue over a
period and are recurring at regular or irregular intervals.
The backbone of the IDDE program is the IDDE Ordinance that the City passed in June 2012 (at the same
time as its Phase II and Falls Lake New Development Ordinances). This ordinance was revised on
February 12, 2019. The IDDE ordinance provides permits specific discharges into the MS4 as legal,
provides legal authority to restrict illegal discharges, prohibits illicit connections, provides conditions for
cleaning up and preventing polluted spills, provides for right of entry into property to investigate
prohibited activities, and provides the City with options for enforcing the Ordinance. The IDDE
Ordinance is based on the NC DWQ’s Model Ordinance.
The second basis for the IDDE program is the City’s MS4 Map. The City’s mapping effort is completed.
The map includes the entire MS4 system and provides for easy access to aid in the investigation of illicit
discharges. An investigator with the map could find an illicit discharge and then easily follow the flow of
the discharge upstream until finding a source of the discharge. The map is available for use through GIS
and is printable for non-GIS users.

MS4 Sample Map

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2018
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The IDDE program also includes dry weather testing of outfalls into the stream system. In the first
permit cycle this is conducted in coordination with the mapping. Outfalls that have dry weather flows
are reported and investigated.
In 2018 the City of Roxboro’s personnel found and corrected one Private Storm drain failure overflow.
No illicit connections, reports of illegal dumping, or rerouted wastewater to stormwater connections
were found. The City did not smoke test or do video inspections in the sewer and stormwater systems
in 2018.
The City’s Capital Improvement Budget for 2018-2019 included extensive evaluation of the City’s
collection system in an effort to reduce surface water and waste water interactions. This included
$250,000 for a study of the Marlowe’s Creek Outfall line and an additional $150,000 for infiltration and
inflow evaluation. Both studies are intended to reduce the potential for wastewater and surface water
interactions.
City Staff are trained on an annual basis as needed to identify illicit discharges and the reporting process
for these discharges. This training is combined with the Pollution Prevention and Good Housekeeping
training of public works, utilities, and some administrative staff. A possible future improvement would
be multiple trainings annually and/or including personnel from other departments including fire and
police personnel. Training of new hires might also be a good addition.
Construction Site Runoff Controls
The City of Roxboro delegates the Construction Site Runoff Controls to the NC DEQ Division of Land
Quality. The City of Roxboro does not have a delegated erosion control program but does make sure
that plans it approves that will disturb greater than 1.0 acres of land apply for, and receive, and erosion
control plan. The City of Roxboro also has the ability to call NC DEQ to report known sedimentation
issues. A possible improvement could be NC DEQ’s responsiveness to City generated complaints, which
has been less than effective in the past.
Post Construction Site Runoff Controls
The City of Roxboro has a typical NPDES Phase II Post Construction Program. This includes a Post
Construction Ordinance, administrative forms that support it, and a review process. The Post
Construction Program is intended to treat two different watersheds. The northern portion of Roxboro is
in the Roanoke River Watershed and has only typical NPDES Phase II Stormwater Controls. The southern
portion of the City drains to the Neuse River and is within the Falls Lake Watershed. The Falls Lake
Watershed is subject to both the Water Supply Watershed restrictions and the Falls Lake Rules
restrictions. The below table further explains the differences in the two watersheds.
City of Roxboro Stormwater Annual Report
2018
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The City passed its New Development Ordinance in June 2012 (Revised Feb. 12, 2019) and the ordinance
contains language explaining the different watersheds and establishing the different standards. The
City’s ordinance also allows for the Stormwater Administrator to require peak flow matching for the 100
year – 24 hour storm.

When a project is submitted to the City it goes through the City Planning Department. During the review
process, Public Services Director Andrew Oakley, P.E. reviews the project from both a stormwater and a
utility perspective. At that point review comments are made about the project and addressed. After
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2018
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approval of the project, the owner is required to complete an Operation and Maintenance Agreement
for the stormwater control measures. This O&M agreement is then recorded with the register of deeds
so that it can reviewed at a later point in time.
In 2018 the City of Roxboro conducted seven plan reviews, one of which triggered the Stormwater
Ordinance, and no projects were completed.
The City of Roxboro requires as-builts and annual inspection reports from new stormwater control
measures (SCM).
Pollution Prevention and Good Housekeeping
Pollution Prevention is an overall goal of the City’s stormwater management plan and Good
Housekeeping is a key to that goal. Municipalities, in general, conduct many activities that can pose a
threat to water quality. Municipal facilities are the primary potential source of contamination but with
good housekeeping habits this potential can be reduced or eliminated. The City attempts to minimize
stormwater pollution from municipal operations by complying with best management plans for each
City facility. The BMP’s are written into a City Facilities O&M Plan that is intended to reduce or eliminate
stormwater exposure of oil, grease, pesticides, herbicides, fertilizers, sediment, and other materials
used by the City. Each of the City facilities is inspected annually and any issues are noted, written into
the Facility O&M Plan, and discussed with the facility supervisor.
The City operates a City Hall/Fire Department, Police Station, 2 Fire Substation, Public Services Facility,
Water Treatment Plant, Wastewater Treatment Plant, and an Old Public Works Facility. Each of these
facilities is inspected annually and any new facilities will be added to the inspection list.

Salt Storage at Public Works
City staff with the greatest exposure to stormwater are trained on PPGH once annually. The training is
combined with illicit discharge detection and elimination training. The PPGH portion of the training
concentrates on good housekeeping functions. This often includes identification of bad habits that can
take place and how to fix the situation to reduce the risk of pollution to stormwater.
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2018
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Approximately 48 tons of salt and 6000 gallons of salt brine were used during inclement weather in
2018. The City also recycled 1017 gallons of used oil with Noble Oil Services in 2018.
The City of Roxboro sweeps the entire cities streets on a weekly basis, which they estimate to be 800
miles a month. The City’s sweeping operation picked up 350 tons in 2018. Culverts and storm drains are
cleaned by jet truck and hand as needed. The City contracts out outfall cleaning.
The City maintains four pet waste signs or stations.
Impaired Waters and Total Maximum Daily Loads (TMDL)
The City of Roxboro discharges to one impaired stream in the Roanoke River Basin and a different
portion of the City is in the Falls Lake Watershed. The impaired stream is Marlow Creek. Marlowe Creek
(22-58-12-6b) is impaired for aquatic life. The Falls Lake Watershed is covered later in this report.
Falls Lake Rules
A portion of the City of Roxboro is within the Falls Lake Watershed and is subject to the Falls Lake
Nutrient Strategy. The Falls Lake Rules were adopted in January 2011 to restore water quality in the lake
by reducing the amount of pollution entering upstream. The rules are a staged nutrient management
strategy designed to reduce nutrient discharges to the lake from various sources, including stormwater
runoff from new and existing development, wastewater treatment plants and agriculture. The following
rules are often referred to as the Falls Lake Rules.:
15A NCAC 02B .0275 - Purpose and Scope
15A NCAC 02B .0276 - Definitions
15A NCAC 02B .0277 - Stormwater Management for New Development
15A NCAC 02B .0278 – Stormwater Management for Existing Development
15A NCAC 02B .0279 – Wastewater Discharge Requirements
15A NCAC 02B .0280 – Agriculture
15A NCAC 02B .0281 – Stormwater Requirements for State and Federal Entities
15A NCAC 02B .0282 - Options for Offsetting Nutrient Loads
15A NCAC 02B .0235 – Amended Neuse River Basin Stormwater Requirements
15A NCAC 02B .0315 – Amended Neuse River Basin

Falls Lake Background, Rules, and Implementation Schedules
The Falls Lake Project was begun in 1978 by the U.S. Army Corps of Engineers. Construction was
completed in 1981. The lake was created to provide flood control, drinking water supply, protection of
downstream water quality, fish and wildlife conservation, and recreation.
Following questions in 2004 over the condition of Falls Lake, DWQ began more intensive sampling for
use support assessment. A Falls Lake Technical Advisory Committee (TAC) was formed in July 2005 to
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2018
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assist DWQ with the review and modification of the monitoring strategy and developing levels of
confidence for decision making associated with the monitoring and lake modeling activities. The field
study was completed in fall 2007. Based on water quality data collected between 2002 and 2006, Falls
Lake was listed as impaired for chlorophyll a on the draft NC 2008 303(d) list. The portion of the lake
above I-85 was also listed as impaired for turbidity.
Following the impairment listing and completion of the study a watershed and lake model were
completed by NC DWQ staff in later 2008 and early 2009 and presented to the TAC for their review. At
the same time a stakeholder process was conducted to educated watershed stakeholders on lake issues,
modeling basics and results, as well as strategy design issues and options. In 2009 and 2010 NC DWQ,
with input from stakeholders, drafted the Falls Lake Rules that would be approved by the Environmental
Management Commission in November 2010.
The Falls Lake Rules are designed to protect and improve water quality in the lake. Specific issues
addressed by the rules include reducing pollution from wastewater discharges, stormwater runoff from
new and existing development, agriculture and fertilizer application.
The primary rules that affect local governments (like the City of Roxboro) are the Stormwater
Management for New Development, Stormwater Management for Existing Development, Protection of
Existing Riparian Buffers, Wastewater Discharge Requirements, and Options for Offsetting Nutrients
Loads. The Protection of Existing Riparian Buffer Rules impacts development within the watershed but is
implemented by NC DENR while the Wastewater Discharge Requirements do not apply to Roxboro
because Roxboro’s water supply and wastewater discharge are both in the Roanoke River Watershed.
The New Development Program’s went into effect in 2012 and are discussed in the above section of the
report with the NPDES Phase II Post Construction Program. The City of Roxboro adopted the first stage
of its Existing Development Program in January 2012. The first stage for Roxboro was to complete a
“Stage 1 Inventory.”
Existing Development Stage 1 Programs
The City of Roxboro’s Stage 1 Inventory included information about its Wastewater Collection System,
Discharging Sand Filter Systems and Septic Systems within the City, Potential Restoration Opportunities
in Utility Corridors, Fertilizer Management Plans, Structural Stormwater Practices, and Restoration
Opportunities for Wetlands and Riparian Buffers.
In the future, the City will need to establish a Stage 1 Nutrient Reduction Program that will contain plans
to reduce any post-baseline loading within the City’s jurisdictional area to the baseline loadings. This
reduction and plan will be established at a later date but the reduction required within Roxboro will be
limited because all development with the Falls Lake Watershed in Roxboro is also within the Water
Supply Watershed and has had at least a partial offset of nutrient loading. Additionally, development
within the last 5 years has been limited within the Falls Lake Watershed.
City of Roxboro Stormwater Annual Report
2018
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Future Existing Development Stage 2 Programs
The City of Roxboro will probably be required to establish a Stage 2 Existing Development Program in
2021. This program will be intended to continue the Stage 1 program and for the City of Roxboro to
provide either of the following:
A. Achieve additional annual reductions in nitrogen and phosphorus loads from existing
development greater than or equal to the average annual additional reductions achieved in the
last seven years of Stage I.
B. Provide for an annual expenditure that equals or exceeds the average annual amount the local
government has spent to achieve nutrient reductions from existing development during the last
seven years of Stage I.

However, it is certainly possible, perhaps even probable that the regulations governing Stage 2 will
change before 2021.
Falls Lake Annual Report
The City of Roxboro has had no staffing changes within this past year, Andy Oakley is the Public Services
Director. In 2018 there were two voluntary Roxboro annexation areas in the Falls Lake watershed, both
are in the design phase with no development currently. There was one development project for storage
units on Old Durham Road, the remaining projects were deck and shed additions that are exempt from
the rules. There was one BMP installed, but because it was for redevelopment of an industrial site the
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2018
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BMP was for flow control. There were no enforcement actions taken this year for violations of program
requirements.

Stormwater Funding
The City of Roxboro funds it’s Stormwater Programs through a Stormwater Fee. The City collects a flat
fee from utility users within the City Limits. The City uses this fee to pay for its Water Quality Programs
including its NPDES Phase II, Falls Lake, and Street Sweeping Programs. The FY 18 Adopted Stormwater
Budget was $250,000.00.
In the future, the stormwater budget will need to be increased in order to cover additional expenses for
the Falls Lake Rules. These increases may be offset by converting the current flat fee into an Existing
Residential Unit (ERU) style fee. The ERU is based on an impervious area per property calculation and
will be a more equitable distribution of stormwater costs than the flat fee is. However, the ERU will have
a substantially higher startup and maintenance costs than the current fee has. The future cost of Falls
Lake may be offset by completion of the MS4 Mapping Program.
The Future of Stormwater
Stormwater, and Water Quality in particular, is an evolving field of regulation. The City of Roxboro is
already involved in NPDES Phase II and Nutrient Sensitive Waters. Within the next decade the City needs
to plan for further regulation of these issues as well as several other outstanding issues. EPA continues
to work on two potentially large future items that include a Numerical Nutrient Criteria for all surface
waters and a National Stormwater Rule. The Numerical Nutrient Criteria is an EPA supported push
towards establishing nutrient limits for all surface waters. Currently in North Carolina, generally only
reservoirs have nutrient limits and the limits are based upon response indicators. The National
Stormwater Rule, underway since late 2009 and sometimes called NPDES Phase III, will likely address the
following four water quality standards:
• Designated uses of a water body, such as recreation, water supply, aquatic life, or agriculture.
• Water quality criteria to protect designated uses, such as the metals criteria discussed above as
part of North Carolina's ongoing triennial review.
• Antidegradation policies that maintain and protect existing uses and high quality waters from
pollutant discharges that unnecessarily degrade those waters.
• General policies to address program implementation issues.
The proposed wording of the rule is available at this time, and can be found here
http://water.epa.gov/lawsregs/lawsguidance/wqs_index.cfm, although its implementation schedule is
unclear but it is expected that it will include a step forward in the City’s NPDES Stormwater Program.
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2018
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Stormwater Program Contacts

Name Position Phone #Email
Andrew Oakley Public Services Director [phone] [e-mail]
Josh Johnson Stormwater Engineer [phone] [e-mail]
Tommy Warren Assistant City Manager [phone] [e-mail]