NCS000247_WinstonSalem NPDES MS4 Phase I_Self-Audit Report_20220505

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PHASE I PROGRAM SELF -AUDIT REPORT
NPDES PERMIT NO. NCS000247
CITY OF WINSTON-SALEM, NORTH CAROLINA
101 North Main Street
City Hall, Suite 53
Winston-Salem, N.C. 27101
Self -Audit Timeframe: April 7, 2022 to May 4, 2022
Report Date: May 5, 2022
I ( I
NCS000247 Winston-Salem 2022 MS4 Self -Audit

Self -Audit Certification
By my signature below, I certify, under penalty of law, that I am a Duly Authorized Representative* and 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.
Name: Mr. Lee Garrity
Title: City Manager
Signature: 0 / Date: �
�/y145 vl
* A Duly Authorized Representative can be the Mayor, City Manager, or an authorized person or position.
To be authorized, a Delegation of Signature Authority Form signed by the Mayor or City Manager must
be on file with the Department.
NC5000247 Winston-Salem 2022 MS4 Self -Audit

TABLE OF CONTENTS
Self -Audit Details, I I I I I I I I I I I I 1 0 1 1 11 1 1 1 1 1 1 1 1 1 1 1 0 1 0 0 a 0 1 0 1 1 1 4 11 0 1 0 6 1 0 4 a * A 0 0 *a 0 0 1 0 0 1 A . 0 h 0 1 1 0 1 , 0 1 0 4 0 . . . 0 0 P 0 4 4 0 4 0 0 0 1 . . I . 1
0 1 0 . . I I . 0 1 . I I . I I . I I . I . . . . I . 0 , 4 0 0 1 1
PermitteeInformation.....................6..0411..111111141111111.........1001.0.16111111116111411.0111..11011111111111111611.I..I..I.I.01......1011012
List of Supporting Documents. I I I I I I I I I I I I I I I I I . I I I . I . I 1 64
......... 0 .... 3
Program Implementation, Documentation & Assessment...........................................................................5
Public Education and Outreach, I I I I I I I I I I I I a I I I I I I I I 1 6 1 1 1 1 1 1 9 6 N too I I a 1 4 6 a 4 1 1 a I a 0 0 1 4 t 0 N 0 0 4 1 1 1 1 1 1 t 0 1 a 0 1 6 t 0 4 N 4 0 1 1 1 1 1
1 1 1 1 4 0 0 V a I 1 0 4 0 0 4 a a 1 0 4 0 1 . . . . I . . I.68
Public Involvement and Participation.....................................................................................0...................11
Illicit Discharge Detection and Elimination(IDDE)......................................................................................15
Construction Site Runoff Controls..."..,,.,.." . I I 40W40,4 . I . . I a I I I I V 1 0 1 1 1 1 4 V I I I o I a V I a V a I I 1 4 4 6 1 0 6 1 1 too I 1 0 1 a 6 1 0
1 1 1 1 a a 6 1 d 6 a I I 1 4 1 a I I a I I I I I o 1 1 4 1 1 1 8
Post -Construction Site Runoff Controls.....................................................................................................120
Pollution Prevention and Good Housekeeping for Municipal Operations....,..,..,......
11 11 1 110404427
Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems....................................132
WaterQuality Assessment and Monitoring................................................................................................35
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................38
Site Visit Evaluation: Municipal Facility No. 2.............................................................................................40
Site Visit Evaluation: MS4 0utfaII No. 1......................................................................................................42
Site Visit Evaluation: MS4 Outfall No. 2........................................................................................11140000400...44
Site Visit Evaluation: Construction Site No. 1...................................................:..........................:.............I.46
Site Visit Evaluation: Construction Site No. 2..............................................................................................48
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................50
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2...........................................152
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000247 Winston-Salem 2022 MS4 Self -Audit iii

Self -Audit Details
Audit ID Number:
Self -Audit Date(s):
NCS000247_Winston-Salem 2022 MS4 Self -Audit
April 7, 2022 to May 4, 2022
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
X Public Education & Outreach
® Public Involvement & Participation
® Illicit Discharge Detection & Elimination
® Construction Site Runoff Controls
® Post -Construction Site Runoff Controls
• Pollution Prevention and Good Housekeeping for Municipal Operations
® Program to Monitor and Control Pollutants
M Water quality Assessment & Monitoring
Field Site Visits:
❑ Municipal Facilities. Number visited: Choose an item.
❑ MS4 Outfalls. Number visited: Choose an item.
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: . Number visited: Choose an item.
❑ Other: . Number visited: Choose an item.
Auditors
Name
Title
Andrew Allen
Assistant Stormwater Director
Keith Huff
Stormwater Director
Audit Report Author
Andrew K. Allen
May 5, 2022
Name
Date
Assistant Stormwater Director
��
ace, ago,
Title
Signature
Audit Report Author
Keith D. Huff
May 5, 2022
Name
Date
Stormwater Director
Title
Signature
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 1 of 54

Audit Report Author
Name Date
Title Signature
Audit Report Author
Name Date
Title Signature
Permittee Information
MS4 Permittee Name:
City of Winston Salem
Permit Effective Date: Permit Expiration Date:
October 10, 2018 October 9, 2023
Mailing Address:
P.O. Box 2511 Winston-Salem,
N.C. 27102
Date of Last MS4 Inspection/Audit:
June 2011 by SAIC (EPA -contracted auditors)
Permit Owner of Record:
City of Winston Salem
Primary MS4 Representatives Participating in Audit
Name
Title
Vicki Pigg
Stormwater Operations Analyst
Ladonta'Jamal' Clark
Stormwater Operations Supervisor
Joseph Fogarty
Stormwater Engineer
Matthew Osborne
Erosion Control/Floodplain Manager
NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 2 of 54

List of Supporting Documents
Item
Number
Document Title
Document Format
(web link, a - file, etc.)
1
City of Winston-Salem's FY 2021-2022 Stormwater Management Plan
PDF
2
Stormwater Division's IDDE SOP Manual
PDF
3
An Example of the Stormwater Division's Notice of Violation and Supporting
Documentation of Successful Completion
PDF
4
BMPs for Public Educational Goals and Objectives
PDF
5
Public Educational Outreach Counts
Excel
6
Municipal NEW Employee Training Counts
Excel
7
Municipal Employee PP&GH and IDDE Training Video Confirmation
Excel
8
Stormwater Smart FY 2020-2021 Summary Report
PDF
9
Stormwater Smart 2022 Invoice
PDF
10
Municipal ALL (other than new) Employees Stormwater Training Video
Excel
11
Chapter 75, Article I —the City of Winston Salem's IDDE Ordinance
PDF
12
FY 2021-2022 Dry Weather Outfall Screening SOPS and Schedule
PDF
13
The Stormwater Division's IDDE Discharge Master Spreadsheet for FY 2021-2022
Excel
14
DEMLR's Review Results Letter of the Winston-Salem/Forsyth County Erosion
Control Program, Dated November 20, 2017
PDF
15
Erosion Control Division's Webpage Screen Shot of Pollution Hotline for
Reporting Violations
PDF
16
Screen Shot of Erosion Control's Flow -Process for Redirecting Project that use
any Public Funds to DEMLR, Winston-Salem Regional Office
PDF
17
The City of Winston-Salem's Post -construction Stormwater Ordinance
PDF
18
The City of Winston-Salem's SCM Operation and Maintenance Agreement
Templates for Homeowner Associations and Single Owners
PDF
19
Escrow Agreement Template for Homeowner Associations
PDF
20
The Stormwater Division's Inspection Master List of Municipal Facilities and
Operations
PDF
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 3 of 54

21
Municipally -owned Stormwater Control Measures (SCMs) Inventory List
PDF
22
The Stormwater Division's FY -2020 to 2022 Inspected Municipal and Industrial
Facilities and FY 2022-2023 Proposed Facilities to Inspect
PDF
23
The Stormwater Division's Industrial and Municipal Inspection Form Template
PDF
24
An Example of a Municipally -owned Stormwater Pollution Prevention Plan
(SPPP) of Fleet Services (Template)
PDF
25
An Example of a Municipally -owned Spill Response Plan of Fleet Services
(Template)
PDF
26
Field Operations' MS4 Inspection and Maintenance Program SOPS
PDF
27
Street Sweeping Log of Municipally -owned Facilities/Parking Lots for FY 2021-
2022
Excel
28
Reference Lists of Small and Large Quantity Generators (SARA Title III) and Toxic
Release Inventory (Hazardous Waste, Disposal, and Recovery Facilities)
PDF
29
Master List of General and Individual Permitted Industrial Facilities within the
Municipal Boundaries of Winston-Salem
PDF
30
The Stormwater Division's Industrial Inspection SOP Manual
PDF
31
Priority 1 and 2 Industrial and Municipal Facilities List, FY 2020-2023
PDF
32
The Stormwater Division's Water Quality Assessment and Monitoring Plan
PDF
NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 4 of 54

Program Implementation, Documentation & Assessment
Staff Interviewed:
Andrew Allen, Assistant Stormwater Director. Mr. Allen creates and discusses Stormwater Management Plan
(Name, Title, Role)
(SWMP) requirements to pertinent team members for the upcoming permit year. In addition, Mr. Allen is
responsible for conducting an annual program evaluation, gap analysis, and as a result, generation of the next
year's SWMP.
Permit Citation
Program Requirement
Status
supporting
Doc No,
ILA.
The permittee maintained adequate legal mechanisms, such as regulations,
Program
ordinances, policies and procedures to implement all provisions of the Stormwater
Yes
1
Implementation
Management Plan (SWMP).
The permlttee implemented provisions of the Stormwater Management Plan and
evaluated the performance and effectiveness of the program components annually.
Yes
The permittee maintained written procedures for implementing the six minimum
control measures, which identify specific action steps, schedules, resources and
Yes
responsibilities.
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see storm water e-payments on https://deq.nc.gov/sw).
Yes
---
Comments
The FY 2021-2022 SWMP contains the elements denoted in Section ILA. As a component of evaluating program effectiveness, the
responsible party completes their section of the annual report and the Assistant Stormwater Director performs a gap analysis. The
results of the gap analysis are discussed with the responsible party with accepted action items infused into the SWMP and
programmatic implementation.
III.
The permittee-maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs, monitoring
Documentation
and sampling, implementation of BMPs, enforcement actions and other stormwater
Yes
activities.
Documentation is kept on -file by the permittee for a period of five (5) years.
Yes
The permittee's Stormwater Management Plan is reviewed and updated as
necessary, but at least on an annual basis.
Yes
Comments
No major programmatic changes occurred in the City's Stormwater Management Plan from PY 2016 to 2019, thus the annual report
did not change, other than the number of completed permit compliance measures. Multiple gap analyses were performed, but
only a portion of recommended actions were implemented. Reasons for non -implementation include, but not limited to, resource
limitations, staffing factor and COVID-19.
IV'B'
The permittee submitted annual reports to the Department by October 31st of each
Annual Reporting
calendar yearfor the previous fiscal year's activities (from July 1"tojune 301h).
Yes
---
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Management Plan, including, but not limited the following:
NCS000247_Winston-Salem 2022 M54 Self -Audit Page 5 of 54

Program Implementation, Documentation & Assessment
a. A detailed description of the status of implementation of the Stormwater
Management Plan. This includes information on development and
implementation of each major component of the Stormwater Management Plan
Yes
for the past year and schedules and plans for the year following each report.
b. A description and justification of any proposed changes to the Stormwater
Management Plan. This includes descriptions and supporting Information for the
proposed changes and how these changes will impact the Stormwater
No
Management Plan (results, effectiveness, implementation schedule, etc.).
c. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Yes
—
Management Plan.
d. A summary of data accumulated as part of the Stormwater Management Plan
throughout the year along with an assessment of what the data indicates.
Yes
—
e. An assessment of compliance with the permit, information on the establishment
of appropriate legal authorities, inspections, and enforcement actions.
Yes
f. Discussion of program funding.
Yes
--
Comments:
Admittingly, the Stormwater Division did not include and implement all proposed changes from multiple gap analysis from PY 2016
— 2019 in the Stormwater Management Plan. Gap analyses results were denoted and submitted to the corresponding responsible
party for implementation. Reasons for non -implementation include, but not limited to, resource limitations, staffing factor and
COVID-19.
IVD.
The Permittee maintained a record of any illicit discharge that reaches waters of the
Other Information
state and may cause or contribute to a violation of the water quality standards or
Yes
2,3
constitute an imminent threat to health or the environment.
The record includes dates, identification of possible responsible parties, causes, and
any action taken by the permittee or the responsible party.
Yes
Discharges that constitute an imminent threat to health or the environment were
reported within 24 hours by phone or e-mail to the Division Regional Office during
business hours, or to the NC Division of Emergency Management State Operations
Yes
---
Center hotline outside of business hours.
Comments
The Stormwater Division issues a Notice of Violation (NOV) to the responsible entity for illicit discharges or dumping that reach (or
have the potential) the City's MS4 system or waters of the state. Each NOV states the required compliance items, due date, and
potential fines, if action items are not completed. The Winston-Salem/Forsyth County Emergency Management and /or
Stormwater Division staff notifies WSRO Regional Office, if imminent danger to public health is determined or if the National
Response Center is notified. Please reference the attached example of an issued NOV and supporting compliance documentation
that demonstrates the Stormwater Division's IDDE process for successfully eliminating pollutants to the MS4 and receiving waters.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 6 of 54

Program Implementation, Documentation & Assessment
Additional 1) The Stormwater Division has uploaded the latest version of its Stormwater Management Plan for PY
Comments: 2020-2021 for DEC's reference. Stormwater staff performed a comprehensive overhaul of its Plan
with respective work outcomes to be reported to DEQ this upcoming annual report.
2) The Stormwater Division has uploaded its IDDE SOP Plan for DEQ's reference.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 7 of 54

Public Education and Outreach
Staff Interviewed:
Vicki Pigg, Stormwater Operations Analyst, supervised the Senior Community Educator from November 2021-
(Name, Title, Role)
April 2022. As of April 19, 2022, the job position of Senior Community Educator is vacant.
Permit Citation
Program Requirement Status supporting
Doc No.
11.B.2.a.
The permittee described the target pollutants and target pollutant sources that the
Target Pollutants
Yes 4
public education program is designed to address and why they are an issue.
& Sources
Comments
The Senior Community Educator maintains a master document regarding best management practices for Public Education and
Outreach and Public Involvement and Participation activities for the Stormwater Division. This document includes programmatic
objectives, materials and programs developed, and goals for the Stormwater Division related to Public Education, Outreach and
Public Involvement. This document is living and updated, as needed. Further and complete details regarding the selected BMPs for
Public Ed/Outreach/Public Involvement. is available in the attached FY 2021-2022 Stormwater Management Plan and FY 2020-2021
Annual Report.
This document is called "BMP for Pub Ed Intro Goals Objectives.docx" and resides here: (G:\Stormwater Educator- Education
Outreach Public Involvement\SOPS\WordDocs of SOPS). Please reference the attached BMP document for DEQ's review.
11.B.2.b.
The permittee described the target audiences likely to have significant stormwater
Target Audiences
impacts and why they were selected.
ves
4
Comments
The Senior Community Educator evaluates and shifts educational outreach focus, as needed, to address the needs and requests of
the community. Method behind making these changes is documented in the "BMP for Pub Ed Intro Goals Objectives.docx" and this
document lives here: (G:\Stormwater Educator - Education Outreach Public Involvement\SOPS\WordDocs of SOPS)
Examples of minor shifting education focus: If we get more automotive related complaints, we address them with targeted
education in the form of handouts or mailers (completed targeted mailer in 2020 to automotive businesses in the Salem Creek
Watershed with English and Spanish information). We have gotten several more pet waste related complaints in 2020 and 2021 and
targeted those neighborhoods with pet waste related door hangers and information. We also did several social media posts to
NextDoor and Facebook to reach other homeowners and residents concerned about pet waste and worked with Stormwater
SMART (and the committee) to choose pet waste as one of the mass media outreach topics for the region. Handouts available upon
request.
II.B.2.c.
The permittee promoted and maintained an Internet web site designed to convey the
Informational
Yes
S
Web Site
program's message.
NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 8 of 54

Public Education and Outreach
Comments
The Stormwater Division's webpage is located at www.City ofws.org/stormwater.
The main topics on Stormwater's website are (and corresponding, supporting minimum measure):
1) Main page— buttons to pay stormwater bill, post construction stormwater, help keep our waterways clean, storm drainage
maintenance, info inside bar how to contact City Link
2) Do your part —volunteering information (public involvement and participation information)
3) For businesses — stormwater runoff information for businesses (industrial/commercial BMPs-targeted audience)
4) For residents —stormwater runoff information for residents (public involvement)
5) Fun stuff— kid's activities for educational awareness and growth (targeted audience for public outreach)
6) Capital improvement projects— information about current capital improvement projects (public involvement)
7) Report polluters— how to report polluters (IDDE program component)
8) Staff —staff listing (IDDE and public involvement)
9) Stormwater management — information about stormwater management program (public involvement and participation)
10) Stormwater runoff— information about stormwater runoff (public education and outreach)
11) Stormwater survey (public involvement and participation)
12) Stormwater billing and utility rate— information about stormwater utility fees (public education and outreach)
13) Erosion Control Information: https://www.City ofws.org/733/Erosion-Control (Construction Site Runoff Controls)
14) Drainage Maintenance Related Information: https://www.City ofws.org/1325/Drainage-Maintenance (Municipal
Good housekeeping and Pollution Prevention)
11.B.2.d.
The permittee distributed general stormwater educational material to appropriate
Public Education
Yes
5
target groups as likely to have a significant stormwater impact.
Materials
Comments
Please reference the attached spreadsheet from November 2018 to the current for the number of distributed educational
materials. This spreadsheet resides at: G:\Stormwater Educator - Education Outreach Public Involvement\Ed & Outreach Programs
Spreadsheet title is "Ed_Outreach—Counts.xlsx"
For workload data collected prior to November 2018, staff consults the spreadsheets saved at this location: G:\Stormwater
Educator -Education Outreach Publiclnvolvement\Ed & Outreach Programs\Ed & Outreach Counts from Roseann 2010-2018-
11•B•2•e•
The permittee promoted and maintained a stormwater hotline(s) or helpline(s) for
Stormwater
the public to request information about stormwater, public involvement &
Yes
Hotline
participation, and to report illicit connections & discharges, etc.
Comments
In 2005, City Council commissioned the creation and implementation of a centralized telephone call center/web-based complaint
hotline for the citizens of the City of Winston-Salem. Known to the public as City Link, this communication center receives citizen -
generated a -mails or telephone calls regarding stormwater-related items illicit within the City. The public can access City Link from
the City of Winston-Salem's homepage of https://www.City ofws.org/; the City Link button appears at the top portion of the City's
homepage and the City Link contact information appears at the bottom of all City webpages. On the Stormwater Division's
homepage on the City website, the City Link contact information is provided at the top of the page. The City Link contact
information is shared on every public brochure made available by the Stormwater Division, On May 14, 2021, The City of Winston-
Salem added a Chat feature to our City website which enable citizens to communicate via chat with our City Link staff. The Chat icon
is in the bottom right hand of the City webpage. The Senior Community Educator receives electronic notifications for presentation
requests from City Link or directly from website requests. Illicit discharges are received through the Stormwater Pollution Hotline
(336-727-8000). which is operated by City Link, City Link refers all illicit discharge complaints to Stormwater staff, who will
investigate these reports within 24 hours.
NCS000247_Winston-Salem 2022 M54 Self -Audit Page 9 of 54

Public Education and Outreach
11.6.2.f. The permittee's outreach program, including those elements implemented locally or
Public Education through a cooperative agreement, include a combination of approaches designed to Yes 5,6,7,8,9,
& Outreach reach the target audiences. 10
Program
Implementation For each media, event or activity, including those elements implemented locally or
through a cooperative agreement, the permittee estimated and recorded the extent Yes
of exposure.
Comments
All public participation and public education and outreach activities are documented in the Stormwater Division's Annual Report
every year and submitted to NC DEQ. A spreadsheet is also maintained with the relevant workload information (list of programs, p
of attendees, etc.). See attached spreadsheets (for November 2018 onward - G:\Stormwater Educator- Education Outreach Public
Involvement\Ed & Outreach Programs, Spreadsheet title is "Ed_Outreach Counts.xlsx". For data prior to November 2018, please
see spreadsheets saved in this folder: G:\Stormwater Educator - Education Outreach Public Involvement\Ed & Outreach
Programs\Ed & Outreach Counts from Roseann 2010-2018).
The Stormwater Division is a participating member of Stormwater SMART, a regional consortium of NC Piedmont communities that
provides stormwater public education services for participating members. In addition, the Stormwater Division contributes
financially each year to Stormwater SMART for the generation of educational materials and media outreach. Stormwater SMART
submits its annual report to consortium members to document their activities/outreach efforts (see attached annual reports from
Stormwater SMART). Media campaigns completed by the Stormwater Division are documented in a report from the vendor with
the engagement results and other mass media outreach efforts done by the Stormwater Division are all saved here: G:\Stormwater
Educator - Education Outreach Public Involvement\Mass Media.
Additional None
Comments:
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 10 of 54

Public Involvement and Participation
Staff Interviewed:
Vicki Pigg, Stormwater Operations Analyst, supervised the Senior Community Educator from November 2021-
(Name, Title, Role)
April 2022. As of April 19, the job position of Senior Community Educator is vacant.
Permit Citation
Program Requirement Status supporting
Doc No.
II.C.2.a.
Volunteer
The permittee included and promoted volunteer opportunities designed to promote
Community
Yes 3
Involvement
ongoing citizen participation.
Program
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 11 of 54

Public Involvement and Participation
The City of Winston-Salem has implemented the following programs to various degrees inor er to promote volunteer
opportunities and ongoing citizen participation:
• Creek Week is a week-long series of events geared to engage the public and support water quality awareness. Events
usually include Creek Crawls, photo contest, guided paddles and nature walks, lunch and learn presentations, a community
read and book discussion, professional development workshops, homeowner and resident workshops, special children and
teen's programs at the public libraries, community clean-ups, water centered recreational activities, and other interactive
programs. Creek Week occurs in March and is organized by a committee of municipal, county, and non-profit
organizations.
• Creek Crawls are held with local school classes where the students visit a nearby creek to examine the water quality of the
stream using water quality test kits and visual observations. Benthic macroinvertebrates are collected, examined, and
discussed as to form an overall assessment of the water quality of the selected stream. Students are taught to collect
water samples and to identify the macrolnvertebrates collected based on provided keys as part ofthis 'hands on'
approach.
• The Stormwater Division co -coordinates the Adopt -A -Stream program with Keep Winston-Salem Beautiful to reduce litter,
debris, and floatables in our waterways. Homeowner associations, companies, special interest groups, families or other
interested parties can request to Adopt -A -Stream in their area of interest. Interested parties will commit to conducting
three clean-ups per year and the City will provide signage and debris removal after each cleanup. Keep Winston-Salem
Beautiful also coordinates Adopt -A -Street and Adopt -A -Park programs to reduce litter, debris, and floatables in our
community.
• Big Sweep is conducted every year in October to remove trash and debris from local waterways.
• The Great American Clean -Up in Winston-Salem is conducted every year in April to remove trash and debris from local
streets, parks, and waterways.
• The Stormwater Division coordinates the Storm Drain Marking program where volunteer groups place adhesive 'No
Dumping, Drains to Creekmarkers or use a provided storm drain marking stencil and spray paint on catch basins and other
drainage structures within the community. Volunteer groups also distribute door hangers that contain Stormwater
education material informing citizens about fertilizer use, pet waste and illegal dumping within targeted neighborhoods
due to the number of reoccurring complaints.
• The Stream Watch in Winston-Salem program encourages volunteers to visit local Winston-Salem waterways to make
various visual observations about the habitat and water quality. Observations are shared through a paper survey emailed
back to the stormwater division. Volunteers are provided with Winston-Salem specific stormwater and stream educational
information to help guide them through their visual observations. Volunteers are encouraged to report any illicit
discharges they observe while participating in Stream Watch in Winston-Salem.
Please reference the attached spreadsheet for Stormwater volunteer participation (for November 2018 onward - G:\Stormwater
Educator -Education Outreach Public Involvement\Ed &Outreach Programs, Spreadsheet title is "Ed_Outreach_Counts.xlsx". For
data prior to November 2018, please see spreadsheets saved in this folder: G:\Stormwater Educator- Education Outreach Public
Involvement\Ed & Outreach Programs\Ed & Outreach Counts from Roseann 2010-2018). KWSB maintains records of KWSB
sponsored clean-ups and shares these with the Stormwater Division for reporting purposes.
These programs are all advertised on the Stormwater Website (https://www.City ofws.org/718/Do-Your-Part) or KWSB website
(https://www.City ofws.org/405/Keep-Winston-Salem-Beautiful) or through advertising completed by the Marketing and
Communications Department (via the City's own social media or other paid advertising).
NC5000247_Winston-Salem 2022 M54 Self -Audit Page 12 of 54

Public Involvement and Participation
II.C.2.b.
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Public
provides for input on stormwater Issues and the stormwater program.
Yes
---
Involvement
Comments
The City of Winston-Salem has three main mechanisms for public input on stormwater issues as well as soliciting feedback
regarding Stormwater's Management Plan; these three mechanisms include City Council Committee meetings, Stormwater Appeals
Board, and City Link's'suggestion and comment' service. The City Council (and Public Works Committee) have established open
public meetings that citizens are invited to attend to discuss any stormwater-related topic. Public Works Committee meetings are
advertised on the City's website and are held the second Tuesday of every month. City Council convenes twice a month - every
meeting has an open floor segment, where citizens may voice their stormwater-related concerns. The Stormwater Appeals Board
has been created to hear appeals if an owner, developer, engineer or other party disagrees with the decision of Stormwater staff.
As of late, the Public Works Committee of the City Council has heard any appeals and carried them to resolution. City Link has
instituted a citizen 'suggestion and comment' service request that allows any citizen to submit suggestions or comments, which
relates to the Stormwater Management Program. These suggestions or comments are forwarded to the Department Head for
review and implementation, if approved.
The permittee promoted and maintained a hotline/helpline for the public to request
II.C.2.c.
information about stormwater, public involvement & participation, and to report
Yes
---
Hotline/Help Line
illicit connections & discharges, etc.
Comments
In 2005, City Council commissioned the creation and implementation of a centralized telephone call center/web-based complaint
hotline for the citizens of the City of Winston-Salem. Known to the public as City Link, this communication center receives citizen -
generated a -mails or telephone calls regarding stormwater-related items illicit within the City. The public can access City Link from
the City of Winston-Salem's homepage of https://www.City ofws.org/ or by the chat feature on the City of Winston-Salem's
webpage; the City Link button appears at the top portion of the City's homepage and the City Link contact information appears at
the bottom of all City webpages. On the stormwater Division's homepage on the City website, the City Link contact information is
provided at the top of the page. The Senior Community Educator receives electronic notifications for presentation requests from
City Link or directly from website requests. Illicit discharges are received through the Stormwater Pollution Hotline (33&727-8000),
which is operated by City Link. City Link refers all illicit discharge complaints to Stormwater staff, who will investigate these reports
within 24 hours.
II.C.2.d.
The permittee made the most recent Stormwater Management Plan available for
Public Comment
public review and comment.
Yes
---
Comments
The current Stormwater Management Plan was posted to the Stormwater Division's webpage in November 2021. One can locate
the Stormwater Management Plan at https://www.City ofws.org/DocumentCenter/View/22898/Stormwater-Management-Plan-FY-
2021-2022-pdf
The permittee complied with State, Tribal and local public notice requirements when
II.C.2.e.
Public Notice
implementing the public involvement / participation program.
Yes
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 13 of 54

Public Involvement and Participation
Comments
The City of Winston-Salem complies with applicable public notice requirements, when implementing its public involvement and
participation program. Compliance with 40 CFR 122.34 is achieved by working with the City Secretary's Office, Marketing and
Communications and the Community Assistance Specialist for scheduling, advertising, and posting public meetings.
Additional None
Comments:
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 14 of 54

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Ladonta 'Jamal' Clark, Stormwater Operations Supervisor, oversees, manages, and enforces the Stormwater
(Name, Title,
Division's IDDE program for permit compliance.
Role)
Permit Citation
Program Requirement Status supporting
Doc No.
II.D.2.a.
The permittee maintained adequate ordinances or other legal authorities to prohibit
Legal Authorities
illicit connections and discharges and enforce the approved IDDE Program. Yes 11
Comments: City Council adopted the City's Illicit Discharge Ordinance in September 2005, Currently, the City of Winston Salem's
IDDE ordinance is contained within Municode, Chapter 75, Article I. Stormwater staff uses the City's IDDE ordinance for regulatory
compliance to cease illicit discharges and connections from entering the MS4/receiving waters. The program involves identifying
and eliminating illicit substances and materials; staff issues Notices of Violations (NOVs) to the offending entity for permanent
resolution of illicit activity. The base file address is: G: JTechn Pro%ects_Files JIDDE- Complaints and NOVs. The file address for the
Chapter 75 ordnance Is: G: jTechnProjects Files)IDDE -Complaints and NOVsiChapter 75 Article
1002.1b.
The permittee maintained a current map showing major outfalls and receiving
M$4 Mapping
Yes
---
streams.
Comments
The City's GIS database is comprehensive; the Stormwater Division contracts a professional engineering firm, HDR, to collect
stormwater inventory (e.g., pipes, structures, major SDOs, etc.) and the corresponding attribute data on a regular basis. A NC
licensed surveying firm, MLA, performs in -field data collection and assessment services with HDR integrating the GIS data into the
appropriate geodatabase layer (as well as performing proper QA/QC data checks). MLA and HDR (and Stormwater staff) ensure
that all inventory is collected to the applicable major stormwater discharge diameter (36 inches for residential zoned land use areas
or drainage areas greater (or equal) than 50 acres OR 12" in industrial zoned land areas or drainage areas greater (or equal) to two
acres. In addition, all stormwater infrastructure within the City's right-of-way Is mapped and enters the geodatabase layer, as well,
since the City owns and operates this system. The City's GIS data is housed in its SDE database and operates in the ArcMap
program. The stormwater inventory map can be used to track the connectivity of pipes to locate illicit discharges.
For FY 2021-2022, HDR has concentrated inventory reconnaissance activities in Lower and Middle Creek Subwatersheds, Upper and
Lower Muddy Creek Subwatersheds, portion of Lower Silas Creek Watershed, and a section of Upper Peters Creek Watershed.
These areas were selected due to prioritized impaired segments of TMDLs watersheds and routine watershed masterplan updates.
Approximately 2,300 major SDOs were inventoried, and 14 miles of streams were assessed. Also, identified inventory that needed
updating due to various capital improvement projects, were surveyed and corrected.
II.D.2.c.
The permittee maintained written procedures and/or Standard Operating Procedures
Dry Weather Flow
(SOPS) for detecting and tracing the sources of Illicit discharges.
Yes
2
Program
The permittee maintained written procedures and/or Standard Operating Procedures
(SOPS) for removing the sources or reporting the sources to the State to be properly
Yes
permitted.
The permittee maintained written procedures and/or SOPS that specify a timeframe
for monitoring and how many outfalls and the areas that are to be targeted for
Yes
12
inspections.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 15 of 54

Illicit Discharge Detection and Elimination (IDDE)
Comments
Please reference the attached Item #2, IDDE SOP Manual, for documentation of these above -mentioned BMPs. In addition, please
reference the attached document, Item #4— FY 2021-2022 Dry Weather Outfall Screening SOPs and Schedule that shows this year's
timeframe and targeted stream segments for dry weather screening activities. Item #4 is a standalone document from the IDDE
SOP Manual but bolsters the City's IDDE program. For this upcoming permit year, Stormwater staff will evaluate FY 2021-2022
water quality data to determine the most impaired stream segments, then create a prioritization list for SDO and stream -walking
reconnaissance activities.
II.D.2.d. The permittee conducted training for appropriate municipal staff on detecting and
Employee Training reporting illicit connections and discharges.
Yes
10
Comments
During FY 2021-2022, the Sr. Community Educator, Stormwater Operations Analyst, and the City's Marketing and Communications
Department created a new training video that highlights proper pollution prevention & municipal goodhousekeeping practices for
key City operations to eliminate pollutant exposure to the environment. A main topic in this video pertains to recognizing and
reporting illicit discharges/dumping activities to Stormwater staff, so more incidents can successfully resolve by Stormwater staff,
thanks to 'rank and file' City team members. From November 2021 to March 2022, 2,127 out of 2,354 City employees (90.3%)
viewed and passed a confirmation test of Stormwater's new PP & MGH and IDDE training video.
II.D.2.e.
The permittee maintained and publicized reporting mechanism(s) for the public to
Public Reporting
report illicit connections and discharges.
Yes
---
Comments
City Link, the City's centralized citizen reporting center, receives phone calls, emails, social media apps, and Internet inquiries for a
myriad of City resource requests. As an option of reporting, citizens can file illicit discharge/dumping claims to City Link. Once a
City Link Customer Service Representative intake the complaint, an automated email message (with all pertinent case information)
is sent to the Stormwater Operations Supervisor (SOS), Stormwater Operations Analyst, and Assistant Stormwater Director (ASD).
Next, the SOS or ASD assigns the service request to a Stormwater Technician (or responds themselves, if staff is busy with their
current workload. The City publicizes City Link by using communicative means of the internet, radio, and television - please
reference the embedded link below. City Link's contact number is [phone].
In addition, Stormwater Division maintains a reporting illicit discharges option on-line at https://www.City ofws.org/817/Report-
Polluters. This webpage contains City Link's contact number and general questions to collect illicit discharge information.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 16 of 54

Illicit Discharge Detection and Elimination (IDDE)
I I. D.2.f.
Documentation The permittee documented the date of investigations, any enforcement action(s) or Yes 3, 13
remediation that occurred.
Comments
Stormwater staff tracks and documents every IDDE complaint and investigation by various means. Rock Solid is the service request
database that the City uses to intake, track, and manage all IDDE complaints. If Stormwater staff receives IDDE complaints directly,
these complaints are entered into Rock Solid. Each cataloged service request is date and time stamps by the responsible person; all
information cannot be erased, once entered. Rock Solid displays the status of the service request — staff manually needs to change
the status, once compliance items have been successfully completed. Apart from Rock Solid, every IDDE investigation has its own
electronic folder on the G: drive and the responding staff member completes an investigation report, which documents the date,
address, location, parcel identification number, finding of facts, and resulting compliance actions to be taken (if warranted). All
enforcement actions are documented in the form of a Notice of Violation (NOV) -this enforcement mechanism explicitly states
what corrective actions are required by the offering party, due date, and potential fines, if corrective actions are not completed. As
a component of the NOV, the offending party must submit remedial documentation (if applicable) to the Stormwater Division, or a
staff member must perform a site inspection to confirm successful completion of all required measures. The responding
Stormwater staff member(s) documents all successful measures via photographs, information documentation in Rock Solid, email,
and inspection reports, once all measures are confirmed by Stormwater staff, a successful completion letter is issued to the
responsible party. Lastly, a master Excel spreadsheet tracks all pertinent information of each IDDE investigation, which includes
resolution date, POCs, inspector, etc. —the incident location is mapped on a master GIS layer for a geographical reference. The City
has attached this master Excel spreadsheet for DEC's reference.
Additional
Comments:
NC5000247_Winston-Salem 2022 MS4 Self -Audit Page.17 of 54

Construction Site Runoff Controls
Staff Interviewed:
Matthew Osborne, Erosion Control/Floodplain Program Manager
(Name, Title, Role)
Program Delegation Status:
The permittee has a delegated Sediment and Erosion Control Program to implement the North Carolina Sedimentation Pollution
Control Act (SPCA) of 1973 and Chapter 4 of Title 1SA of the North Carolina Administrative Code.
The delegated or authorized Sediment and Erosion Control Program effectively meets the NPDES MS4 MEP standard
for Construction Site Runoff Controls by permitting and controlling development activities disturbing one or more acres
of land surface and those activities less than one acre that are part of a larger common plan of development as authorized
under the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code.
Permit Citation Program Requirement Status Supporting
Doc Na.
II.E.2.a.
Delegated SPCA The permittee implements a delegated program in compliance with the
Program Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the Yes JA
North Carolina Administrative Code within the City's jurisdictional area.
Comments (Note date of last SPCA delegated program review by NCDEQ-DEMLR staff and result)
The most recent delegated program review by NCDEQ-DEMLR staff was July 25, 2017. The result of the delegated program review
was a recommendation by NCDEQ-DEMLR staff to continue delegation of the program.
II.E.2.c.
The permittee provided and promoted a means for the public to notify the
Reporting
appropriate authorities of observed erosion and sedimentation problems.
re:
15
Mechanism
Comments
Yes, through information provided on our Erosion Control website (https://www.City ofws.org/733/Erosion-Control). The public
can call the City of Winston-Salem's Pollution Hotline at [phone] or 311 to report sedimentation discharge claims. Citizens
can email City Link at City link@City ofws.org to report these claims as well.
II.E.2.d.
The permittee coordinated the approval of the construction site runoff control with
Coordination with
DEMUR for new development and redevelopment projects to be built within the
Yes
16
DEMUR
permittee's planning jurisdiction by entities with eminent domain authority.
Comments
Projects with eminent domain authority are referred/forwarded to NCDEQ-DEMLR staff at the Winston-Salem Regional Office by
providing a standard comment of referral on plan reviews where Erosion Control staff determine it to be applicable. All projects
that receive public funding (from governmental agencies, full or partially funded) are referred/forwarded to NCDEQ-DEMLR staff at
the Winston-Salem Regional Office for review and approval.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 18 of 54

Construction Site Runoff Controls
Additional None
Comments:
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 19 of 54

Post -Construction Site Runoff Controls
Staff Interviewed:
Joe Fogarty, Stormwater Engineer. Reviews and approves submitted plans for compliance with City's post -
(Name, Title, Role)
construction ordinance. Ensures all operation and maintenance agreements for SCMs are properly
executed and recorded. Oversees Stormwater staff (or performs) concerning SCM inspections (private and
public) and ensures appropriate correspondence to transmitted to responsible parties.
Program Implementation (check all that apply):
® The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: list name of entity
❑ The permittee implements the following Qualifying Alternative Program(s), which meet NPDES M54 post -construction
requirements in the areas where they are implemented and in compliance with the specific program requirements as provided in
15A NCAC and noted below:
❑ Water Supply Watershed I (WS-1) —15A NCAC 213.0212 (Eff. March 1, 2019 15A NCAC 02B .0620-.0624)
❑ Water Supply Watershed II (WS-11) —1SA NCAC 28 .0214 (Eff. March 1, 2019 15A NCAC 026 .0620-.0624)
❑ Water Supply Watershed III (WS-III) —15A NCAC 2B .0215 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
❑ Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 (Eff. March 1, 2019 15A NCAC 02B .0620-.0624)
❑ Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 2B ,0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 2B .0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Regulatory Authority:
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements (check all that apply):
❑ DEQ model ordinance
® MS4 designed post -construction practices that meet or exceed 15A NCAC 02H :1000
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved Qualifying Alternative Program listed above
Program Requirement Status supporting
Doc No.
The permittee implements the Qualifying Alternative Program requirements
No
checked above in accordance with the applicable 15A NCAC rules.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 20 of 54

Post -Construction Site Runoff Controls
02H .1017
The permittee cumulatively implements the Qualifying Alternative Program
Qualifying
No
requirements checked above throughout the entire MS4 permitted area.
Alternative
Program(s)
If response is no or partial, the permittee implements MS4 post -
construction requirements in accordance with 15A NCAC 02H .1017(3) —
Yes
17
(14) throughout the balance of the MS4 permitted area.
Comments
Permit Citation Program Requirement Status supporting
Doc No,
II.F.2.a. The permittee maintained an ordinance or similar regulatory mechanism that
Legal Authority authorizes a program to address stormwater runoff from new development and Yes 17
redevelopment to the extent allowable under State law.
Comments
The Stormwater Division oversees and enforces the City's post -construction stormwater management program. The City of
Winston-Salem has supplemented previous water supply watershed regulations with current post -construction regulations for Class
'C' waters in order to address stormwater runoff from new and redeveloped sites. The current Post Construction Stormwater
Management ordinance was adopted by the City Council on September 19, 2008, and this ordinance applies to all development
within our jurisdictional area (municipal boundary). The City's Post -construction Ordinance can be located at
https://I ibra ry. m un icod e.com/nc/wi nston-salem/codes/code—of—ordinances?nodel d=PTI I ICOO R—CH75STMA_ARTI V POCOST,
II.F.2.b.
The permittee maintains strategies that include a combination of structural and/or
Stormwater Control
non-structural SCMs in concurrence with the legal authorities above (II.F.2.a.).
Yes
Measures (SCMs)
The permittee provides a mechanism to require long-term operation and
maintenance of structural SCMs.
Yes
---
The permittee requires annual inspection reports of permitted structural SCMs
Yes
performed by a qualified professional.
The permittee implements SCM requirements that are at least as stringent as the
Yes
17
minimum requirements in 15A NCAC 02H .1000.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 21 of 54

Post -Construction Site Runoff Controls
The City ofWinston-Salem's Post Construction Stormwater Management ordinance provides sizing and performance criteria for
water quality and quantity SCMs. The City of Winston-Salem has also adopted the State's Stormwater Design and NCDOT Linear
Transportation Toolbox as technical guides for designing structural SCMs within Its jurisdictional area and thus for use in also
providing sizing and performance criteria, in combination with the ordinance provisions. The ordinance addresses both low density
and high -density development scenarios as regards water quality attenuation. Low density developments (less than 24 percent
built upon area, or less than two dwelling units per an acre) must meet all the Minimum Design Criteria (MDC) of the NC DWR
Stormwater Design Manual —Low Density Chapter, to the maximum extent practicable. Such items include but are not limited to
recording of stream buffers where applicable and using vegetative conveyances to the maximum extent practicable. High density
developments (greater than 24 percent built upon area and more than two dwelling units per acre) in addition to meeting all the
low density non-structural SCM requirements, to the maximum extent practicable, must also provide structural SCMs. Any SCM or
combination of SCMs that are considered 'Primary' SCMs per the Stormwater Design Manual and that can be effectively
constructed in the Piedmont physiographic region may be approved by the Stormwater Engineer or Stormwater Director. In
addition, the Post Construction Stormwater Management ordinance also includes a local requirement for water quantity standards
if a development creates more than 20,000 square feet of new impervious area. If that is the case a development must either, (a)
design structural SCMs in order to mitigate detrimental downstream effects of flooding and erosion in various design storm events,
or in lieu of management provide a "no adverse impact downstream study" if indeed a no adverse impact situation can be proven.
Stormwater staff inspect approved water quantity SCMs (pre-2008 post -construction ordinance adoption) as well as the Salem Lake
Watershed (Water Supply IV Classification) SCMs on an annual basis. Next, Stormwater staff informs the owners of record of any
deficiencies noted so that they may be addressed. Operation and Maintenance Agreements are required to be approved, recorded
and Implemented for all the developments located within the Salem Lake Watershed area that require SCM(s) and the owners of
such SCMs are bound to the terms of that agreement.
SCMs, within the City limits jurisdiction and approved after the adoption of the post -construction ordinance, must have an
Operation and Maintenance Agreement recorded as part of the post construction permit process that is binding on the SCM owner.
The responsibility of SCM inspection and maintenance is placed on the designated SCM owner, or Homeowners
Association/Property Owners Association, as applicable, who has signed the recorded Operation and Maintenance Agreement. The
requirements for such inspections and maintenance are outlined in an Operation and Maintenance Manual that forms part of the
overall Operation and Maintenance Agreement. Beginning after the certification of the as -built drawings for a permitted
stormwater management system, the system must be inspected per the frequency described in this agreement by a suitably
qualified professional on behalf of the owner. The owner must keep all records of these inspections and any maintenance activities
that may have been necessary and submit these records to the Stormwater Director for review on an annual basis. The Stormwater
Director or his designee may carry out his own inspection to validate such submitted records.
II.F.2.c.
Deed Restrictions The permittee provides mechanisms such as recorded deed restrictions, plats,
and Protective and/or protective covenants so that development activities maintain the project Yes 18
Covenants I consistent with approved plans.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 22 of 54

Post -Construction Site Runoff Controls
Comments
The City of Winston-Salem created, adopted, and implemented its post -construction ordinance on September 19, 2008. This
ordinance includes comprehensive regulatory procedures in order to ensure compliance. Right of entry drainage and access
easements must be granted to the City to inspect, monitor, maintain, repair, or to reconstruct the stormwater management system
as necessary and these easements are referenced in the recorded Operation and Maintenance Agreements, Notice of Violations,
remedies, and monetary penalties are examples of regulatory tools contained within the post -construction ordinance that the
Stormwater Division utilizes as enforcement mechanisms. For further reference, the City's Post -construction Stormwater Control
Ordinance (Chapter 75, Article IV) can be located at this link: https:Hlibrary,municode.com/nc/winston-
salem/codes/code_of_ord ina nces7nodeld=PTI I ICOOR_CH75STMA_ARTI VPOCOST
II.F.2.d.
The developer provides the permittee with an operation and maintenance plan for
Operation and
the stormwater system, indicating the operation and maintenance actions that
Maintenance Plans
shall be taken, specific quantitative criteria used for determining when those
Yes
18,19
actions shall be taken, and who is responsible for those actions.
The plans clearly indicate the steps that shall be taken and who shall be responsible
for restoring a Stormwater system to design specifications if a failure occurs.
No
18
The plans include a legally enforceable acknowledgment by the responsible party.
No
18
Development is maintained consistent with the requirements in the approved
plans.
yes
18
Modifications to those plans must be / are approved by the Permittee,
yes
18
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 23 of 54

Post -Construction Site Runoff Controls
SCM5, within the City limitslurs on and approved after the adoption of the 2008 Post -construction Ordinance, must have an
Operation and Maintenance Agreement recorded as part of the post construction permit process that is binding on the SCM owner.
The responsibility of SCM inspection and maintenance is placed on the designated SCM owner, or Homeowners
Association/Property Owners Association, as applicable, who has signed the recorded Operation and Maintenance Agreement. The
requirements for such inspections and maintenance are outlined in an Operation and Maintenance Manual that forms part of the
overall Operation and Maintenance Agreement. Beginning after the certification of the as -built drawings for a permitted
stormwater management system, the system must be inspected per the frequency described in this agreement by a suitably
qualified professional on behalf of the owner. The owner must keep all records of these inspections and any maintenance activities
that may have been necessary and submit these records to the stormwater Director for review on an annual basis. The Stormwater
Director or his designee may carry out his own inspection to validate such submitted records.
All structural SCMs approved in accordance with the Post -Construction stormwater Management ordinance must have a financial
surety that meets the requirements of the ordinance provisions, in force prior to permit issuance. For a developer who wants to
remain the party responsible In perpetuity for the long-term Operation and Maintenance of the system, a payment into the City's
Catastrophic Failure Fund shall equal four percent of the estimated construction cost of the stormwater management system,
verified by submittal of a sealed engineers estimate. This payment is maintained a City account and is non-refundable. The
developer may apply for a loan from this account if needed to address system deficiencies. For SCMs that are to be owned and
operated by a HOA or POA, then the surety that is required is in the form of an escrow account and escrow agreement. The
developer establishes an escrow account at the time of permitting and deposits 15 percent of the estimated construction cost of
the stormwater management system into this account, with the HOA/POA to add further funds in the future. An escrow agreement
must be approved and recorded during the permit process, which allows the City access to this escrow account, and its funds if
needed should a SCM owner fail to comply with maintaining the system.
II.F.2.e.
Educational
Materials and The permittee provided educational materials and training for developers. Yes
Training
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 24 of 54

Post -Construction Site Runoff Controls
Comments
Multiple training and information sessions were provided by Stormwater Division staff prior to and after the ordinance
implementation in 2008. Educational materials provided include a permit application flowchart, example of design calculations and
other supplementary information such as Operation and Maintenance Manual templates. These are available on the Stormwater
Division's website. The Stormwater Engineer, and if needed, the Stormwater Director, also make themselves regularly available to
meet with developers at their request on an individual basis if they need guidance on permit policies and procedures before
applying for a permit. The Stormwater Engineer is also a member of the City's Technical Review Committee (TRC) and attends in
person meetings held on a weekly and monthly basis to explain the post -construction stormwater management permitting process
to applicants looking to develop or redevelop property within the City limits and Salem Lake Watershed, The Stormwater Engineer
has on average three such meetings (individual plus TRC combined) on a weekly basis. The Stormwater Engineer fulfills multiple
meetings and information requests from developers, owners, and citizens either by phone or e-mail on a weekly basis outside of
the in -person meetings.
Currently, the Stormwater Director and Stormwater Engineer regularly attend a Developer Forum and Planning Board meeting to
inform interested parties regarding the post -construction permitting, potential communal negative impacts, and other pertinent
post -construction stormwater management topics.
The City maintains a website on the Stormwater Divisions webpage that addresses the City's post -construction permitting process
as well as development requirements within the regulated Salem Lake Watershed area. This website is used as an educational tool
available to all developers and SCM owners. The website contains items such as, a link to the Post Construction Stormwater
Management ordinance, a link to the NC DWR Stormwater Design Manual website, the permit flow chart, a link to the permit
application and checklists for submittal, templates for Operation and Maintenance Agreements and Manuals, design examples or
SCMs, templates for inspections and annual compliance reports, a link to the electronic review submittal system and also a detailed
FAQ section that attempts to address most, if not all of the questions that developers and SCM owners typically have. This website
may be found at https://www.City ofws.org/794/Post-Construction-Stormwater-Management.
ll'F'4'
The permittee applies additional requirements to projects draining to SA waters by
Sensitive Receiving
requiring SCMs that result in the highest degree of fecal coliform die -off and
Not
Waters
controls sources of fecal coliform to the maximum extent practicable in accordance
Applicable
with 15A NCAC 02H .1017(9)
The permittee applies additional requirements to projects draining to Trout waters
by requiring SCMs that avoid a sustained increase In receiving water temperature
Not
Applicable
in accordance with 15A NCAC 02H .1017(9)
The permittee implements an approved locally implemented Nutrient
Management Strategy that addresses post -construction runoff and the provisions
Not
Applicable
of that Strategy fulfill the MS4 post -construction requirement.
Comments
None
Permittee Projects
The permittee meets the requirements of the post -construction program for
Yes
17
construction projects that are performed by, or under contract for, the permittee.
NCS000247_Winston-Salem 2022 M545e1f-Audit Page 25 of 54

Post -Construction Site Runoff Controls
Comments
The City's Engineering Department manages and oversees construction projects for the City of Winston-Salem. SCMs, associated
with these construction projects, adhere to Chapter 75 of the City Code. Operation and Maintenance Agreements are held by the
responsible municipal entity, which the SCM's location is physically constructed. For example, if a new fire station is constructed
that warrants post -construction measures (e.g., water quality/quantity SCMs, riparian buffers, etc.), then the Winston-Salem Fire
Department is responsible for maintenance activities.
I L F.6.
The permittee requires that the water quality design volume of SCMs account for
SCM Design Volume
the runoff at build out from all surfaces draining to the system.
yes
F717
Comments
SCM water quality designed volumes are required in the ordinance and implemented at review stage for developments by provision
of drainage delineation plans/maps, as a part of the design documents.
II.F.7.
The permittee fulfills the post -construction minimum control measure
Linear
requirements for non-NCDOT linear transportation projects if they are designed,
Transportation
constructed, and conveyed as set forth in 15A NCAC 02H .1001(1)(c):
Projects
(i) Constructed to NCDOT standards and in accordance with the NCDOT BMP
Toolbox;
Yes
17
(11) Conveyed to NCDOT or other public entity and regulated in accordance with
that entity's NPDES MS4 Permit; and
(III) The project is not part of a common plan of development.
Comments
The City of Winston-Salem utilizes the NCDOT Linear Transportation BMP Toolbox for roads, strollways, greenways and other linear
projects. These may include vegetated conveyances and plunge pools to the MEP.
Additional
None
Comments:
NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 26 of 54

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Name: Ladonta Clark "Jamal"
(Name, Title, Role)
Title: Stormwater Operations Supervisor
Role: (Supervisor)
Supervising Two Stormwater Technicians and One Stormwater Inspector. Oversees the Pollution
Prevention and Good Housekeeping for Municipal Operations/Facilities program.
Permit Citation
Program Requirement
Status
supporting
Doc No,
II.G.2.a.
The permittee maintained an inventory of municipal facilities and operations
Municipal Facility
owned and operated by the permittee that have been determined by the
Yes
20
Inventory
permittee to have significant potential or generating polluted stormwater runoff.
The permittee maintained an inventory of municipally -owned structural SCMs.
Yes
21
Comments
The Stormwater Inspector and/or the Stormwater Operations Supervisor maintains a comprehensive inventory of municipal
facilities and operations. This inventory is very detailed and encompasses pertinent facility/operation Information, such as facility
contact, last date of inspection, priority ranking, located within a TMDL watershed, etc.
The Stormwater Engineer maintains an inventory of structural SCMs that are City -owned. This inventory includes basic
information, which encompasses date of installation, location, type of SCM, pollutants treated, possesses an 0&M Plan, etc.
The link to the exact spreadsheet is here G:\Industrial Inspection & Municipal Good housekeeping\MGH&PP Program\Municipal
Facilities\Master Municipal\Master Municipal.xlsx
Last Updated Date: 10/11/2021 of the Master Municipal Facilities/Operations List.
Last Updated Date: 1/3/2022 of inventory of City -owned SCMs
ILG.2.b.
The permittee implemented an inspection and maintenance program for facilities
Inspection and
and operations owned and operated by the permittee for potential sources of
Yes
22
Maintenance for
polluted runoff, including stormwater controls and conveyance systems.
Municipal Facilities
The inspection program evaluates pollutant sources, documents deficiencies, plans
corrective actions, implements appropriate controls, and documents the
Yes
23
accomplishment of corrective actions.
The maintenance program includes maintenance activities and procedures aimed
at preventing or reducing pollutants generated from municipal facilities and
Yes
23
operations.
NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 27 of 54

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
The Stormwater Division inspects and ensures proper maintenance activities of City -owned facilities or operations by means of the
creation and implementation of a Stormwater pollution prevention plan (SPPP) by the responsible City entity. The Stormwater
Inspector conducts inspections based on the priority level of the facility or operation; higher prioritized sites or operations are
inspected on an increased frequency and/or order. As municipal facilities or operations are inspected, the inspection results (e.g.,
Required Actions to be Completed by the Facility) are incorporated into the Stormwater Division's master tracking list. Inspections
are conducted, recorded, documented, and sent to the responsible municipal entity with required corrective actions that need to
be completed. Each site pollution prevention plan has a maintenance schedule of BMPs, and the Stormwater Inspector monitors
BMP completion by means of site reinspections and/or submitted documentation. The Stormwater Inspector tracks the completion
of all required BMP actions and schedules site reinspections, if the responsible municipal entity does not respond within the
specified due date.
Inspection form folder is hyperlinked here:
G:\Industrial Inspection & Municipal Goodhousekeeping\Inspection Forms\Industrial Inspection Forms
II.G.2.c.
The permittee maintained and implemented Site Pollution Prevention Plans for
Site Pollution
municipal facilities owned and operated by the permittee that have been
Prevention Plans for
determined b the permittee to have significant potential for generating
y p g p g g polluted
Yes
21, 24
Municipal Facilities
stormwater runoff that has the goal of preventing or reducing pollutant runoff.
Comments
If a municipal facility has an NCG permit or possess the size and magnitude of a state -permitted facility, then the created
stormwater pollution prevention plan (SPPP) will follow the outline and contain contents of a general stormwater permit. This
ensures that larger and/or more complex municipal operations/facilities possess a SPPP that is compliant with permit requirements
as well as eliminating pollutant exposure to stormwater. If City -owned facility/operation has the potential to generate pollutants,
but not large or complex, the facility is Issued an abbreviated SPPP. An abbreviated plan consists of numerous aspects of a
permitted -facility SPPP, (e.g., spill response measures, basic facility maps with Stormwater discharge outfalis, good housekeeping
and preventative maintenance schedule, employee training, etc.), but not all SPPP components (e.g., feasibility study, risk
assessment, site maps with topography, etc.).
It is the municipal entity's responsibility to implement all provisions of their assigned SPPP, including updating all pertinent
information, as site or personnel changes occur. General SPPP templates and inspection -generated material are stored digitally on
the Stormwater Division's shared G: drive by Stormwater Inspector or Stormwater Operations Supervisor. The Stormwater
Inspector conducts a site inspection to track and monitor the progression of SPPP compliance. When an inspection is completed,
the Stormwater Inspector denotes any required actions that facility will need to perform to maintain SPPP compliance; the
Stormwater Inspector sends an electronic inspection report to the facility for corrections. As the Stormwater Inspector performs
their site inspection, they have access to the facility's current SPPP for comparing site conditions to the Stormwater Division's
Inspection form.
After reviewing the master municipal facilities/operations spreadsheet, Stormwater staff have determined the following breakdown
for SPPPs:
The number of municipally -owned facilities/operations that possess SPPPs (full or abbreviated) = 58
The number of municipally -owned facilities/operations to be evaluated for potential pollutants and SPPP creation = 25
The number of municipally -owned facilities that possess a spill prevention, control, and countermeasure plan = 3
Stormwater staff have digitalized all inspection forms, which are stored at the following hyperlink locations:
G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Completed NIGH SWPPPs
G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Municipal Facilities
NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 28 of 54

Pollution Prevention and Good Housekeeping for Municipal Operations
" The permittee maintained spill response procedures for municipal facilities and
Spill Response operations owned and operated by the permittee that have been determined by
Procedures for Yes 25
the permittee to have significant potential for generating polluted stormwater
Municipal Facilities runoff,
Comments
All spill response procedures (SRP) for municipal facilities are included in every site pollution prevention plan (SPPP). In the event of
a spill, the municipal facility will be able to use their SRPs for mitigating the effects of said spill. In addition, the responsible entity
must keep their SPPP current, which includes SRPs and the spill response team contact information. As the Stormwater Inspector
inspects the facility, he or she denotes if the responsible entity must make any needed changes.
Employee awareness is the key to an effective spill prevention and response program. Spill prevention training is a component of
the general employee training program. New personnel are taught spill prevention practices during the City's new employee
orientation. The spill response team gains a sufficient understanding of the objectives of the spill prevention program. Spill
prevention training highlights previous spill events, equipment failures, remedies taken, and newly developed prevention
measures. The Stormwater Spill Response Team Leader evaluates the spill prevention program at least once each year to keep it
current.
The location
for the
file
location can
be found
here in the hvperlinks:
G:\Industrial
Inspection
& Municipal
Goodhousekeeping\MGH&PP Program\Completed MGH SWPPPs
G:\Industrial Inspection &Municipal Goodhousekeeping\MGH&PP Program\Municipal Facilities
II.G.2.e. The permittee described measures that preventor minimize contamination of the
Vehicle and stormwater runoff from all areas used for vehicle and equipment cleaning, Yes ---
Equipment Cleaning including fire stations that have more than three fire trucks and ambulances.
Areas
The permittee performs all cleaning operations indoors, covers the cleaning
operations, ensures wash water drains to the sanitary sewer system, collects wash yes ---
water and stormwater run-on from the cleaning areas and provides treatment or
recycling, or other equivalent measures
The permittee, if sanitary sewer is not available to the facility and cleaning
operations take place outdoors, ensures wash water drains to an SCM for
treatment, or else the cleaning operations take place on or drain directly to grassed Yes ---
or graveled areas to prevent point source discharges of wash water into the storm
drains or surface waters.
The
permittee,
where cleaning operations
cannot be performed as described above
and
when operations are performed in the
vicinity of a storm drainage collection
system, covers
the drain(s) with a portable
drain cover during cleaning activities,
Yes
and
any excess
standing water is removed
and properly handled prior to removing
the
drain cover.
The permittee facilities that have three or fewer fire trucks and ambulances
attempt to comply with the above requirements; however, those that cannot yes ---
comply with these requirements due to existing limitations incorporate structural
measures during facility renovation to the extent practicable.
NCS000247_Winston-Salem 2022 M54 Self -Audit Page 29 of 54

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
To mitigate any pollutants from being released into the MS4 or receiving waters from vehicle cleaning activities, all vehicle washing
is performed at Fleet Services' Lowery Street location. At that facility, the City of Winston Salem has four wash bays that are
connected to oil and water separators —these separators discharge to the sanitary sewer system. One bay is an automatic wash
bay that fits vehicles 7 foot and lower. Two of the bays wash high clearance vehicles; the other bay is an automatic wash bay for
heavy equipment. All City of Winston Salem employees are advised to use this facility as their main source of vehicle and
equipment cleaning, unless employees use a private auto -washing facility that is connected to the sanitary sewer. All fire stations
have a stormwater pollution prevention plan; Stormwater staff recommended to the Winston-Salem Fire Department to prevent all
wash water from entering the MS4 system during vehicle -washing activities. The WSFD SPPP is located at the following location:
G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Completed MGH SWPPPs\Fire Stations
II.G.2.f.
Streets, Roads and
The permittee implements BMPs to reduce polluted stormwater runoff from
Public Parking Lot
municipally -owned streets, roads, and public parking lots within the corporate
Yes
26, 27
Maintenance
limits.
Comments
Field Operations at City Yard processes an average of 800 service requests annually resulting in over 1,450 work orders each year.
These work orders address a wide variety of maintenance tasks from inlet cleaning to ditch reshaping to structural maintenance. If
structures have observable structural damage, the structure is placed on a prioritization list for future repair or replacement.
Please reference the City's MS4 Inspection, Operation, and Maintenance Plan (I, O, and M) for more detailed information regarding
this permit requirement.
Stormwater staff prioritized the top four parking lots/facilities for street sweeping activities, based on potential pollutant
exportation. These facilities include Fleet Services, Sanitation/Lowery Street car -washing facility, Streets (Field Operations), and the
Winston-Salem Transit Authority (WSTA) Maintenance and Parking Facility. These facilities are swept every other week (on
average) by the City's Sanitation Department.
II.G.2.g.
The permittee maintained and implemented an inspection and maintenance
Inspection and
program for structural stormwater control measures (SCMs) owned and operated
Partial
Maintenance for
by the municipality.
Municipal SCMs and
MS4
The permittee maintained and implemented an inspection and maintenance
program for the municipal storm sewer system (including catch basins, the
Yes
26
conveyance system and SCMs).
Comments
The Stormwater Engineer, a North Carolina licensed professional engineer, inspected all City -owned stormwater control measures
(SCMs) In November 2021. Admittingly, the Stormwater Division has not performed significant maintenance for its SCMs, since
being installed, other than trash/debris removal. Reasons for the lack of significant maintenance activities include, but limited to,
insufficient resources, staffing factor, and COVID-19.
Field Operations at City Yard processes an average of 800 service requests annually resulting In over 1,450 work orders each year.
These work orders address a wide variety of maintenance tasks from inlet cleaning to ditch reshaping to structural maintenance. If
structures have observable structural damage, the structure is placed on a prioritization list for future repair or replacement.
Please reference the City's MS4 Inspection, Operation, and Maintenance Plan (I, 0, and M) for more detailed information regarding
this permit requirement.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 30 of 54

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h. The permittee maintained a training plan that indicates when, how often, and who
Staff Training Yes 6, 10,23
is required to be trained and what they are to be trained on.
The permittee implemented a training plan that indicates when, t and Yes 6110
who is required to be trained and what they are to be trained on.
Comments
In each site pollution prevention plan, there is a section that requires the responsible entity to perform spill response (SR) training.
During the site inspection, the Stormwater Inspector audits the facility's current SR documentation and provides training for staff
when needed. The SPPP requires SR training be done at least once a year and anytime that there is a new employee that has joined
the work force. This type of training is specific to the operation. Also, on the Stormwater Division's inspection form, there is a
question where the Inspector denotes if training has been completed. This question reminds the Inspector to confirm training has
been completed and properly documented (within the Stormwater Management Strategy section of the municipal/industrial
inspection form). The Senior Community Educator and the Stormwater Inspector collaborate and provide educational DVDs that
cover multiple pollution prevention topics to pertinent City employees.
During FY 2021-2022, the Senior Community Educator, Stormwater Operations Analyst, and the City`s Marketing and
Communications Department created a new training video that highlights proper pollution prevention & municipal good
housekeeping practices for key City operations to eliminate pollutant exposure to the environment. A main topic in this video
pertains to recognizing and reporting illicit discharges/dumping activities to Stormwater staff, so more incidents can successfully be
resolve by Stormwater staff, thanks to 'rank and file' City team members. From November 2021 to March 2022, 2,127 out of 2,354
City employees (90.3%) viewed and passed a confirmation test of Stormwater's new PP & MGH and IDDE training video. This
educational video will need to be viewed by all City employees on an annual frequency for maximum memory retention.
Additional I None
Comments:
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 31 of 54

Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems
Staff Interviewed:
Name: Ladonta Clark "Jamal"
(Name, Title, Role)
Title: Stormwater Operations Supervisor
Role: (Supervisor)
Supervising Two Stormwater Technicians and One Stormwater Inspector. Responsible for administering
and ensuring permit compliance with the Stormwater Division's Industrial Inspection Program.
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.H.Z.a.
The permittee maintained an inventory of permitted hazardous waste treatment,
Industrial Facility
disposal, and recovery facilities, industrial facilities that are subject to Section 313
Yes
28
Inventory
of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA).
The permittee maintained an inventory of industrial facilities identified with an
industrial activity (as defined in 40 CFR 122.26) permitted to discharge storm water
Yes
29
to the permittee's MS4.
Comments
The Stormwater Division maintains a comprehensive industrial facility inventory. The Stormwater Inspector consults the
Environmental Protection Agency's databases (via the Internet) to obtain applicable industries, within the municipal boundaries of
Winston-Salem, that are subject to SARA Title III (i.e., RCRA facilities) and permitted hazardous waste facilities (i.e., the toxic release
inventory facilities. Then, the Stormwater Inspector obtains active and expired NPDES Stormwater Permittees from North Carolina
Department of Environmental quality's website within the City limits. The Stormwater Inspector consults EPA's and DEC's websites
annually to maintain a complete and current database.
The file location for all databases is located:
G:\Industrial Inspection & Municipal Goodhousekeeping\Indust_Inspect\City Industrial Information\TRI (updated 4/11/2022)
G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information\RCRA (updated 4/11/2021)
G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information\Active CoCs (updated
4/12/2022)
Source websites of RCRA, TRI, and state -permitted stormwater facilities:
Active & Expired NPDES Stormwater Permits - deq.nc.gov
TRI-. Gathered from USEPA TRI Facilities Search
RCRA- Using USEPA Envirofacts RCRA Lookup
ILH,2.b.
I7 nspection Program
The permittee identified priorities and inspection procedures. At a minimum,
Yes
30,31
priority facilities include those identified above (subsection II.H.2.a).
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 32 of 54

Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems
Comments
When merging RCRA, TRI, active DEQ stormwater permits, and the City's IDDE lists together, the Stormwater Inspector observes the
frequency of each facility's name, The Increased frequency of each repeating name shows the scope and magnitude of industrial
operations, thus, warranting the heightened priority of the facility to be inspected. As a result, these types of facilities are moved
into the top tier for inspection services. After this tiered initial sorting, the Stormwater Inspector uses additional priority -ranking
criteria to finalize the industrial inspection list— this criterion includes historical spills, located within a TMDL watershed, analytical
monitoring data, and major staff or facility changes. The Stormwater Inspector's goal is to inspect every general or individually
stormwater permitted facility once during its permit cycle (every five years)
Please note: The Stormwater Inspector performs inspection activities on RCRA or TRI facilities ONLY If the facility has an active
general or individual stormwater permit or experiences an illicit discharge. This is due to inspection and entry authority reasons;
general (and individual) stormwater permits grant access to local stormwater programs under Section 1-13, if connected to the MS4
as well as Chapter 75, the City of Winston-Salem's Illicit Discharge Ordinance. Otherwise, local, state, and federal regulations do
not provide legal authority for entry and inspection by Stormwater staff into RCRA and TRI facilities.
The Stormwater Division's Industrial Facilities List (of past inspected facilities from FY 2020-2022 and FY 2022-2023 proposed
facilities) is located : G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information,
The Stormwater Division has created and implemented industrial inspection procedures SOPS - these SOPS are located:
G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information\Industrial SOP\Current
II.H.2.c.
The permittee evaluated control measures implemented at permitted hazardous
Industrial Facility
waste treatment, disposal, and recovery facilities, industrial facilities that are
Evaluation
subject to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
Yes
For the purpose of this permit the Permittee is authorized to inspect the permitted
hazardous waste treatment disposal, and recoveryfacilities as an authorized representative
of the Director.
The permittee evaluated control measures implemented at industrial facilities
identified with an industrial activity permitted to discharge storm water to the
permittee's MS4.
Yes
For the purposes of this permit, industrial activities shall mean all permitted industrial
activities as defined in 40 CFR 122.26,
For permitted industrial facilities, the permittee established procedures for
reporting deficiencies and non-compliance to the permitting agency.
Yes
Where compliance with an existing industrial stormwater permit does not result
in adequate control of pollutants to the MS4, the permittee recommends and
documents the need for permit modifications or additions to the permit Issuing
yes
30
authority.
The permittee evaluated control measures implemented at industrial facilities
identified as an illicit discharge under the IDDE Program.
Yes
---
NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 33 of 54

Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems
Comments
The Stormwater Division evaluates all implemented stormwater control measures (SCMs) or best management practices (BMPs) at
TRI, RCRA, and active state -permitted facilities, which have been issued a general or individual Stormwater permit (this includes all
facilities that have experienced an illicit discharge). If SCMs or BMPs are deemed inadequate or have failed, the Stormwater
Inspector denotes all required action items that the facility will need to correct to become compliant with their Stormwater permit.
The Stormwater Inspector determines the specified due date that the facility must implement all corrective measures, based on the
amount and severity of action items that are required.
The Stormwater Inspector and/or the Stormwater Operations Supervisor creates, establishes, updates, and maintains all
procedures for reporting deficiencies and non-compliance to the Winston-Salem Regional Office of DEG, which are listed in our
Industrial Inspection SOP Manual. This manual was updated on April 18, 2022 and located at: G:\Industrial Inspection & Municipal
Goodhousekeeping\lndust_Inspect\City Industrial Information\Industrial SOP\Current. In addition, the Stormwater Division
notifies DEQ WSRO of insufficient measures within existing state stormwater permits via the City's Inspection Form.
When a facility (commercial or Industrial) releases an illicit discharge, the Stormwater Inspector performs a comprehensive
inspection to permanently eliminate the source or connection of said discharge. The Stormwater Inspector incorporates all
inspection documentation into the industrial inspection folder for future reference, as well as into the master industrial
spreadsheet as a criterion for assessment prioritization.
Additional None
Comments:
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 34 of 54

Water Quality
Assessment and Monitoring
Staff Interviewed:
Name: Ladonta Clark "Jamal"
(Name, Title, Role)
Title: Stormwater Operations Supervisor
Role: (Supervisor)
Supervising Two Stormwater Technicians and One Stormwater Inspector. Oversees
and ensure compliance
with the Stormwater Division's Water Quality Assessment and Monitoring Plan.
Permit Citation
Program Requirement
Status supporting
Doc No.
11.1.2.a.
Water Quality
The permittee maintained a Water Quality Assessment and Monitoring Plan.
Yes 32
Assessment and
Monitoring Plan
The Water Quality Assessment and Monitoring Plan includes a schedule for
Yes 32
implementing the proposed assessment and monitoring activities.
NC5000247_Winston-Salem 2022 M54 Self -Audit Page 35 of 54

Comments
The Stormwater Operations Supervisor maintains the City's Water quality Assessment and Monitoring Plan, which was last
modified on April 13. 2022. Stormwater staff performs water quality The Plan resides at: G:\Techn_Projects_Files\WQAM Plan_
Stormwater staff has implemented the Water Quality Assessment and Monitoring Plan —the sampling plan schedule is in Section 9:
Sampling Monitoring Yearly Schedule.
Stormwater staff has summarized the sampling regime contained within the Water quality Assessment and Monitoring Sampling
Plan and is stored at the following location: G:\Techn_Projects_Files\WQAM Plan_\Sampling Summaries,
Fixed Interval Sampling
Fixed Interval sampling is performed quarterly, in all weather conditions, at 13 sites across Winston-Salem's municipal boundaries.
Fixed interval will be carried out on the third week of the first month at the beginning of each quarter. The sites are divided
between two receiving streams: Salem Creek and Muddy Creek— both are TMDL watersheds. There are six sites on Salem Creek
and seven sites on Muddy Creek. The remaining seven sites are in Mill, Silas, Little, Fiddlers, and Lower South Fork Watersheds.
Twenty-four sampling parameters are collected at each site. Most water quality samples are analyzed in a North Carolina certified
laboratory, while several parameters are analyzed using an instanteous water quality meter.
• There are nineteen parameters that are analyzed in a certified laboratory, which includes Biological Oxygen Demand, Total
Cadmium, Total Chromium, Dissolved and Total Copper, Total Lead, Total Nickel, Dissolved and Total Zinc, Total Dissolved
Solids (TDS), Nitrate, Nitrite, Ammonia, Total Kjeldahl Nitrogen, Dissolved and Total Phosphorous, Total Suspend Solids
(TSS), Turbidity (NTU), and Fecal Coliforms.
• Field parameters are gathered primarily by a YSI quatro Pro Plus, This device is used to gather the following five
parameters: Temperature (C), Dissolved Oxygen (%), Dissolved Oxygen, Conductivity(µS/L), and pH. As events arise or
equipment fails, all parameters may be substituted from YSI meters and Pocket Colorimeters and be collected instead by
bottle and taken to Pace Analytical for lab analysis.
Total Maximum Dailv Load (TMDL)
Currently, the City of Winston-Salem has two TMDL watersheds. These two watersheds are Salem Creek and Muddy Creek
Watersheds. TMDL sampling is conducted in five of these watersheds for a total of 22 sites: Upper Salem Creek (six sites), Peters
Creek (five sites), Middle Salem Creek (two sites), Lower Salem Creek (two sites), and Brushy Fork (seven sites).
Sampling is dependent upon ambient weather conditions, so no fixed schedule exists for sampling within the quarter to achieve
desired levels of sampling. All sampling is done in either dry or wet weather conditions, with wet weather being defined as a rain
event of greater than 0.10" in the last 72 hours and anything less being defined as dry weather.
Ten parameters are collected at each site. Some are lab analyzed while most are field gathered.
• The four lab analyzed parameters are Fecal Coliforms, Total Suspended Solids (TSS), Ammonia, and Nitrate. These samples
are collected in sample bottles and placed on Ice before being taken to Pace Analytical Laboratories.
• Field parameters are gathered primarily by a YSI Quatro Pro Plus. This device is used to gather the following six
parameters: Temperature (C), Dissolved Oxygen (%), Dissolved Oxygen, Conductivity(µS/L), Total Dissolved Solids (TDS),
and pH. As events arise or equipment fails, all parameters may be substituted from YSI meters and Pocket Colorimeters,
Water Quality Monitoring
Water quality Monitoring (WQM) sampling is performed quarterly at 18 sites in both dry and wet weather conditions across the
Winston-Salem municipal boundaries. Because WQM sampling is weather dependent, there is no set time frame for this sampling
during the quarter. Fifty percent of WQM samples are expected to be collected during wet weather conditions, which is defined as
occurring within 72 hours of a rainfall event amounting to one -tenth of an inch of precipitation or more. Fifty percent of samples
are also expected to be collected during dry weather conditions, which is defined as occurring at least 72 hours after a rain event of
one -tenth of an inch or more or when there has been less than one -tenth of precipitation. The number of samples collected in dry
and wet weather conditions is reversed for the following quarter of the year to balance the appropriate amount of data for all sites.
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 36 of 54

Water Quality Assessment and Monitoring
The 18 sites used for WQM sampling represent data for several different watersheds within Winston-Salem municipal boundaries.
The percentage of sites representing each watershed from the total 18 sites are as follows:
• Eleven percent of the sampling sites (Lower South Fork at Peters Creek Pkwy and Lower South Fork at Old Lexington Road)
are collected within the Lower South Fork Muddy Creek Watershed.
• Eleven Percent of the sampling sites (Fiddlers Creek at Teague Road and Fiddler's Creek at Willard Road) are collected
within the South Fork Muddy Creek Watershed.
• Eleven percent of the sampling sites (Monarcas Creek at Linn Station Road and Mill Creek at Reynolda Road) are collected
within the Lower Mill Creek Watershed.
• 23 percent of the sampling sites (Mill Creek at Patterson Avenue, Mill Creek at Shattalon Drive, Leak Fork at Hines Park
Soccer Field, and Leak Fork at Motor Road) are collected within the Middle Mill Creek Watershed.
• 29 percent of the sampling sites (Silas Creek at Royall Drive, Silas Creek at Reynolda Village, Silas Creek at Yorkshire Road,
Little Creek at Old Vineyard Road, and Silas Creek at Country Road) are collected within the Silas Creek Watershed.
• Five percent of the sampling sites (Muddy Creek at Country Club Road) are collected within the Lower Muddy Creek
Watershed.
• Five percent of the sampling sites (Peters Creek at Hanes Park) are collected within the Peters Creek Watershed.
• Five percent of the sampling sites (Muddy Creek at Reynolda Road) are collected within the Upper Muddy Creek
Watershed.
During WQM sampling, seven pollutant parameters are collected and measured by utilizing either a YSI Water Quality Meter for
temperature, pH, dissolved oxygen, total dissolved solids, and conductivity or by grabbing a water sample that is taken in for
laboratory analysis for nitrate and ammonia.
11.1.2.b.
The permittee maintained and Implemented the Water Quality Assessment and
Water Quality
Monitoring Plan submitted to DEMUR.
Yes
32
Monitoring
The Division waived the requirement to maintain a Water Quality Assessment and
Not
Monitoring Plan.
Applicable
Comments
The City of Winston Salem has maintained and implemented its Water Quality Assessment and Monitoring Plan, which was
submitted to Jeanette Powell on May 24, 2021,
Additional
None
Comments:
NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 37 of 54