1

OMPREHENSIVE STORMWATER

MANAGEMENT PLAN

FOR

THE CITY OF GRAHAM

JUNE 2017

CONTACT INFORMATION UPDATED

AUGUST 2021

TABLE OF CONTENTS

Table of Contents ............................................................................................................. ii

Definitions ....................................................................................................................... v

1 Storm Sewer System Information ............................................................................. 6

1.1 MS4 Conveyance System .................................................................................... 6

1.2 Land Use Composition Estimates: ........................................................................ 6

1.3 Estimate Methodology: ......................................................................................... 6

1.4 TMDL Identification ............................................................................................... 6

2 Receiving Streams .................................................................................................... 8

3 Existing Water Quality Programs .............................................................................. 9

3.1 Local Programs: ................................................................................................... 9

3.2 State Programs: .................................................................................................... 9

4 Permitting Information. ............................................................................................ 10

5 Co-Permitting Information ....................................................................................... 12

6 Reliance on other government entity to satisfy one or more permit obligations ...... 13

7 Stormwater Management Program ......................................................................... 14

7.1 Public Education and Outreach on Storm Water Impacts ................................... 14

7.1.1 BMP Summary Table ....................................................................................... 14

7.1.2 Target Audience .............................................................................................. 15

7.1.3 Target Pollutant Sources ................................................................................. 15

7.1.4 Outreach Program ........................................................................................... 15

7.1.5 Decision Process ............................................................................................. 15

7.1.6 Evaluation ........................................................................................................ 15

7.2 Public Involvement and Participation .................................................................. 16

7.2.1 BMP Summary Table ....................................................................................... 16

7.2.2 Target Audience .............................................................................................. 17

7.2.3 Participation Program ...................................................................................... 17

iii

7.2.4 Decision Process ............................................................................................. 17

7.2.5 Evaluation ........................................................................................................ 17

7.3 Illicit Discharge Detection and Elimination .......................................................... 18

7.3.1 BMP Summary Table ....................................................................................... 18

7.3.2 Storm Sewer System Map ............................................................................... 19

7.3.3 Regulatory Mechanism .................................................................................... 19

7.3.4 Enforcement: ................................................................................................... 19

7.3.5 Detection and Elimination ................................................................................ 19

7.3.6 Non Stormwater Discharges ............................................................................ 20

7.3.7 Outreach .......................................................................................................... 20

7.3.8 Decision Process ............................................................................................. 20

7.3.9 Evaluation ........................................................................................................ 20

7.4 Construction Site Stormwater Runoff Control ..................................................... 20

7.5 Post-Construction Storm Water Management in New Development and

Redevelopment .................................................................................................. 21

7.5.1 BMP Summary Table ....................................................................................... 21

7.5.2 Stormwater Management Options ................................................................... 22

7.5.3 Non-Structural BMP’s ...................................................................................... 22

7.5.4 Structural BMPs ............................................................................................... 22

7.5.5 Regulatory Mechanism .................................................................................... 22

7.5.6 Operation and Maintenance ............................................................................. 22

7.5.7 Education ......................................................................................................... 22

7.5.8 Decision Process ............................................................................................. 23

7.5.9 Evaluation ........................................................................................................ 23

7.6 Pollution Prevention/Good Housekeeping for Municipal Operations .................. 24

7.6.1 BMP Summary Table ....................................................................................... 24

7.6.2 Affected Operations ......................................................................................... 25

7.6.3 Training ............................................................................................................ 25

7.6.4 Maintenance and Inspections .......................................................................... 25

7.6.5 Vehicular Operations ....................................................................................... 26

7.6.6 Waste Disposal ................................................................................................ 26

7.6.7 Flood Management Projects ............................................................................ 26

7.6.8 Decision Process ............................................................................................. 26

7.6.9 Evaluation ........................................................................................................ 26

7.7 Total Maximum Daily Loads (TMDL) .................................................................. 27

7.7.1 BMP Summary Table ....................................................................................... 27

7.7.2 Determination of TMDL’s ................................................................................. 28

7.7.3 Establishing a Water Quality Recovery Plan .................................................... 28

7.7.4 Decision Process ............................................................................................. 28

7.7.5 Evaluation ........................................................................................................ 28

DEFINITIONS

BMP – Best Management Practice also known as a Stormwater Control Measure

Category 4b Plan – An EPA approved plan that is an alternative to a TMDL

DEMLR – Division of Energy, Mining, and Land Resources

DEQ – Department of Environmental Quality (formerly DENR)

EPA – Environmental Protection Agency

Illicit Discharge – Any discharge to an MS4 that is not entirely composed of stormwater.

Exceptions include discharges from NPDES-Permitted industrial sources and

discharges from fire-fighting activities

MS4 – Municipal Separate Storm Sewer System. A conveyance or system of

conveyances (including roads with drainage systems, municipal streets, catch basins

curbs, gutters, ditches, manmade channels, or storm drains)

NPDES – National Pollutant Discharge Elimination System

SCM – Stormwater Control Measure

TMDL – Total Maximum Daily Load

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 6

1 STORM SEWER SYSTEM INFORMATION

Population Served: 14,812 (2016 Estimate from the NC Office of Budget & Management)

Annual Growth Rate: 4.7%

Jurisdictional and MS4 Service Areas: Jurisdictional area: 9.39 square miles,

MS4: 9.39 square miles

1.1 MS4 CONVEYANCE SYSTEM

The City of Graham MS4 consists of a combination of storm drain piping, roadside ditches, and sheet flow. New developments are

required by City ordinance to have curb and gutter drainage systems and high density developments are required to treat the first 1"

of runoff from the developed property. City streets are maintained by the City's Street Department, which is housed in the Public

Works Department. State roads are maintained and managed by NCDOT.

1.2 LAND USE COMPOSITION ESTIMATES:

Residential: 50.04%

Commercial: 23.20%

Industrial: 6.52%

Open Space: 20.24%

1.3 ESTIMATE METHODOLOGY:

The land use estimate was based on the zoning within the jurisdictional area as of June 2009. The Piedmont Triad Council of

Government’s GIS system provided the zoning data, and includes the right-of-way areas.

1.4 TMDL IDENTIFICATION

Town Branch has a TMDL for fecal coli form. The TMDL lists the following non-point sources in the watershed: urban runoff

(stormwater), sewer line systems (leaky sewer lines and sewer system overflows), wildlife, failing septic systems, and probably illicit

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 7

connections in unknown locations. The TMDL does not include an implementation plan. The City of Graham has begun addressing

sanitary sewer overflows through sewer system infrastructure upgrading.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 8

2 RECEIVING STREAMS

Table 1. Cape Fear River Basin

Receiving Stream Name

Stream

Segment

Water Quality

Classification

Use

Support

Rating

Water

Quality

Issues

Haw River 16-(10.5) WS-V; NSW 1, 2, 3 Benthos

Town Branch

16-17 WS-V; NSW Fecal

Coliform

County Home Branch (Still House Branch) 16-17-1 WS-V; NSW NR N/A

Big Alamance Creek 16-19-(4.5)

WS-V; NSW NR N/A

Back Creek (Little Creek) 16-19-5 WS-V; NSW NR N/A

Little Alamance Creek 16-19-11 WS-V; NSW 1, 2 Urban

Stormwater

Bowden Branch (Boyd Creek) 16-19-11-2

WS-V; NSW NR N/A

Aquatic life and secondary recreation

Fish consumption

On 303(d) list

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 9

3 EXISTING WATER QUALITY PROGRAMS

3.1 LOCAL PROGRAMS:

Additionally the City operates a Stage 1 Adaptive Management Program for Existing Development in the Jordan Lake Basin. The

Stage 1 Adaptive Management Program is very similar to the NPDES Phase II Program and is part of a Jordan Lake Watershed

Nutrient Sensitive Waters Strategy.

3.2 STATE PROGRAMS:

NCDEQ implements the NC Erosion and Sediment Control Program within the City of Graham.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 10

4 PERMITTING INFORMATION.

Table 2. Responsible Contacts

Position Name Phone No. Fax No. Email

City Manager / Vacant Frankie Maness 336/570-6700 336/570-6703 fmaness@cityofgraham.com

Interim / Asst. City

Manager

Aaron Holland 336/570/6700 336/570-6703 aholland@cityofgraham.com

City Clerk Darcy Sperry 336/570-6500 336/570-6703 dsperry@cityofgraham.com

Stormwater Engineer

Alley, Williams,

Carmen, & King, Inc.

Josh Johnson 336/226-5534 336/226-3034 [email protected]m

City Public Works

Director

Burke Robertson 336/570-6709 336/570-6703 brobertson@cityofgraham.com

City Attorneys Robert (Bob) Ward

J. Bryan Coleman

336/228-1433 336/570-6703

City Planning Director Justin Snyder 336/570-6700 336/570-6703 jsnyder@cityofgraham.com

Utilities Director Tonya Mann 336/578-3264 336/570-6703 tmann@cityofgraham.com

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 11

Signing Official: City Manager – Frankie Maness - Interim City Manager - Aaron Holland

Duly Authorized Representative: NA

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 12

5 CO-PERMITTING INFORMATION

Not applicable

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 13

6 RELIANCE ON OTHER GOVERNMENT ENTITY TO SATISFY ONE OR MORE PERMIT OBLIGATIONS

The City of Graham will rely on the State Erosion and Sediment Control Program and the

Department of Water Quality’s general stormwater permit program for construction

activities to meet the construction site stormwater runoff control requirement. There are

no legal agreements in place to establish responsibilities.

The City also contracts with the Piedmont Triad Regional Council’s Stormwater Smart

program. The program handles most of the City’s educational responsibilities.

Contact Information:

NC Sedimentation and Erosion Control Program

Winston-Salem Regional Office

Tamera Eplin, P.E.

450 West Hanes Mill Road, Suite 300,

Winston Salem, NC 27105-7407

336/776-9800

Piedmont Triad Regional Council

Stormwater Smart

Dancia Heflin

1398 Carrollton Crossing Drive,

Kernersville, NC 27284

(336) 904-0300 ext. 3008

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 14

7 STORMWATER MANAGEMENT PROGRAM

7.1 PUBLIC EDUCATION AND OUTREACH ON STORM WATER IMPACTS

7.1.1 BMP Summary Table

BMP Measurable Goals

Responsible Position/Party

Maintain an education plan Maintain education plan. Include in Plan the BMPs, schedule,

targeted audiences, and measurable goals. Summarize plan

and implementation progress in each annual report.

X X X X X City Planner

Stormwater Engineer

School Programs Maintain school children education program. Focus on basic

messages regarding clean water and the things they can do at

home to help. Track the number of children reached and the

subject covered and report annually.

X X X X X City Planner

Stormwater Engineer

Mailers, brochures, posters Distribute bilingual mailer for insert in utility bills. Distribute

bilingual brochures and posters for distribution at City Hall.

Target homeowners and businesses with messages about how

they can reduce pollution picked up by stormwater. Track

number of homes and businesses reached by mailer and report

annually.

X X X X City Planner

Stormwater Engineer

City’s web page Link to other stormwater websites. Give tips on reducing

pollution. Report annually.

X X X X X City Planner

Stormwater Engineer

Festivals, parades, local

fairs

Participate in local festivals annually by providing a stormwater

information booth starting. Provide bilingual messages on the

importance of clean water and on specific activities that can be

carried out to help keep stormwater clean.

X X X X X City Planner

Stormwater Engineer

Business and Industry

education and outreach

Maintain program for educating business and industry using

brochures or pamphlets and report annually on number of

businesses reached and number of employees educated. Focus

on workplace issues to reduce pollutant loading. Target hot spot

businesses.

X X City Planner

Stormwater Engineer

Helpline / Hotline All stormwater related calls will be forwarded to the Public Works

Dir. who will then distribute the information to other employees.

X X X X X Public Works Director

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 15

7.1.2 Target Audience

Graham residents, school children, local businesses (including gas station owners

and landscaping companies) and industry, will be targeted because these groups

have the most impact on stormwater pollution prevention.

7.1.3 Target Pollutant Sources

The education program will target total suspended solids and nutrient loading

because turbidity, sedimentation, and nutrients are the pollutants of concern in

downstream waters. In addition, floatables, trash, and debris will also be targeted.

The education program will also address the proper use and disposal of typical

household chemicals, garden chemicals, and used motor oil.

7.1.4 Outreach Program

School programs, printed materials to be distributed via mail and public events,

and participation in state cleanup programs will be used to reach the target

audience. By using these methods, the education program will be expected to

reach all residents of Graham, as well as those that do business here, over the

course of the five year permit period. As a result of this outreach program, the

target audience will be informed of the importance of reducing storm water

pollution and ways they can incorporate pollution reduction in their daily lives.

Direct Education was chosen over mass media due to availability of the

cooperative stormwater education program, Stormwater SMART, and due to

studies showing the effectiveness of direct education over mass media.

7.1.5 Decision Process

The formation of the storm water public education and outreach program was

based on the mechanisms currently in place, and their means and effectiveness

of communicating and educating the public about the issues of stormwater

pollution prevention. Each of the BMP’s selected was judged to be an effective and

economical tool for educating the general public and/or specific groups within the

community, with a specific measurable goal with which to gauge its effectiveness.

7.1.6 Evaluation

The education and outreach program will be evaluated based on how each

individual BMP is meeting its measurable goal at the end of each reporting period.

Changes will be considered for any BMPs that are not meeting the measurable

goals.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 16

7.2 PUBLIC INVOLVEMENT AND PARTICIPATION

7.2.1 BMP Summary Table

BMP Measurable Goals

Responsible Position/Party

Public Meeting A public meeting will be held annually to discuss the

implementation of the permit. This meeting will provide

the public with the opportunity to be involved with the

stormwater program and will serve as a better conduit

for public input than the stormwater committee used

previously. More meetings may be held if public

involvement is substantial.

X X X X X City Planner

City Clerk

Stormwater Engineer

Asst City Manager

Volunteer Stormwater Program The City will promote various volunteer stormwater

programs annually. These will include Big Sweep,

Adopt-A-Stream programs, and Storm Drain Stenciling.

The number of participants will be reported annually.

X X X X X City Planner

Stormwater Engineer

Helpline / Hotline All stormwater related calls will be forwarded to the

Public Works Director who will then distribute the

information to other employees.

X X X X X Public Works Director

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 17

7.2.2 Target Audience

The City’s stormwater committee will be discarded in favor of an annual public

meeting. The public meetings will allow the public an opportunity to review the

stormwater management program and will target all interested and affected

members of the Graham community. Additional meetings may be held if public

involvement is substantial.

The City’s committee was ineffective in soliciting widespread public input.

7.2.3 Participation Program

The public was originally involved in the development of the stormwater permit and

management program through a public hearing in 2005. Public participation

opportunities will be implemented throughout the life of the permit through the

Volunteer Stormwater Programs and the Annual Public Meeting.

7.2.4 Decision Process

A public meeting is necessary for public participation and input. The other BMPs

were selected to give the public a choice of both active and passive participation

roles.

7.2.5 Evaluation

The Public Involvement and Participation program will be evaluated based on how

each individual BMP is meeting its measurable goal at the end of each reporting

period. Changes will be considered for any BMPs that are not meeting the

measurable goals.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 18

7.3 ILLICIT DISCHARGE DETECTION AND ELIMINATION

7.3.1 BMP Summary Table

BMP Measurable Goals

Responsible Position/Party

Review Illicit Discharge Ordinance Review Illicit Discharge Ordinance and make any

necessary revisions.

X X X X X City Attorney

Stormwater Engineer

City Planner

Review Illicit Discharge Program Review Illicit Discharge Program and make any

necessary revisions.

X X X X X Public Works Director

Stormwater Engineer

City Planner

Maintain storm sewer system map

showing outfalls and the receiving

body of water.

Maintain system map in support of inspection program.

The map will note outfalls and receiving body of water

for each outfall. Report annually on progress.

X X X X X Stormwater Engineer

City Planner

Public Works Director

Maintain an inspection and

elimination program within the

community.

Investigate and track any sources of Illicit discharges.

document date, discharge observed, results and the

date problem was corrected.

X X X X X Public Works Director

Stormwater Engineer

Coordinate with local health

department on failing septic systems,

locating problem areas in the system

map. Provide public information on

septic system management.

Provide a fact sheet on septic system management,

Record date of distribution and number of copies

placed.

X X Public Works Director

Stormwater Engineer

City Planner

Train employees on how to inspect

for illicit connections and establish a

tracking system for managing

reported problem areas.

Provide materials through HR to all public employees

in illicit connections and how to recognize one.

Summarize in annual report.

X X X X X Public Works Director

Stormwater Engineer

City Planner

Dry Weather Flow Detection Dry Weather testing will be done at least bi-annually in

accordance with the IDDE program, dependent upon

other IDDE investigations.

X X X X X Stormwater Engineer

Public Works Director

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 19

7.3.2 Storm Sewer System Map

Storm sewer system has been mapped and will be inspected during the course of

normal maintenance operations by the public service department. The route of the

system, locations of pipes, drainage ditches, and outfalls will be maintained on a

paper map and/or electronic map. The map will be updated as needed during

subsequent maintenance operations.

7.3.3 Regulatory Mechanism

The City has an Illicit Discharge Ordinance which allows for inspection,

maintenance, and prohibits illicit discharges.

7.3.4 Enforcement:

There are provisions in the amended ordinance for enforcement actions and

penalties for dumping, spills, and willful illicit connection.

7.3.5 Detection and Elimination

After the field screening is complete, the City will take measures to identify and

remove illegal discharges. Identifying illegal discharges may require a combination

of office and field work. After the field screening, staff will consult the jurisdiction-

wide information they have compiled to obtain information about the land uses,

infrastructure, industries, potential sources and types of pollution that may exist in

the drainage area of the outfall.

After priority areas have been identified in the office, a systematic field

investigation will be planned that minimizes the amount of resources required to

identify the source. The following field methods may be used to identify and trace

the source of illegal discharges:

• Site Investigation

• Dry weather flow observations

• Smoke Testing/Dye Testing

• Television Inspection

The right of entry established in the ordinance will provide access for inspection if

the origin of the discharge is in doubt. Once an illegal discharge is located and

confirmed through field screening, staff will notify the responsible party verbally if

possible and follow-up with written notification. If the responsible party does not

comply with the removal schedule provided by the City, or receive approval for a

revised schedule, the City will take enforcement action and the connection will be

removed at the responsible party’s expense.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 20

7.3.6 Non Stormwater Discharges

Currently there are no known non-stormwater discharges that are a significant

contributor to the MS4. If any are identified in the future, they will be addressed at

that time.

7.3.7 Outreach

City employees will be informed of the hazards associated with illegal discharges

and improper disposal of waste as part of their general training requirements.

These will be addressed in the Pollution Prevention/Good Housekeeping section

of this plan, and will include training in hazardous material handling and disposal,

as well as notices and signs posted in the appropriate areas.

The general public will be educated through the BMP’s listed in the Public

Education section of this plan. These educational BMP’s will include brochures,

public service announcements, and business education and outreach programs.

7.3.8 Decision Process

The formation of the storm water Illicit Discharge Detection and Elimination

program was based primarily on regulatory mechanisms. The regulatory,

educational, procedural BMP’s selected were judged to be an effective means of

detecting and eliminating illicit discharges.

7.3.9 Evaluation

The effectiveness of the program will be gauged by the total number of illicit

connections detected and removed each year and with public complaints. If the

total number remains constant, or increases, changes will be made to the public

education program and/or the City ordinance to allow for greater enforcement and

penalties.

7.4 CONSTRUCTION SITE STORMWATER RUNOFF CONTROL

The City of Graham will rely on the North Carolina State Erosion and Sediment Control

Program and the Department of Water Quality’s general stormwater permit program for

construction activities to meet the construction site stormwater runoff control

requirement.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 21

7.5 POST-CONSTRUCTION STORM WATER MANAGEMENT IN NEW DEVELOPMENT AND REDEVELOPMENT

7.5.1 BMP Summary Table

BMP Measurable Goals

Responsible Position/Party

Review the Post Construction Ordinance Review the Post Construction Ordinance for

compliance with NC DWQ guidance and local

effectiveness. Phase II Post-Construction

Ordinance will incorporate Jordan Lake Nutrient

Strategy Regulations in conjunction with NC

Session Law and DWQ regulations.

X City Planner

City Attorney

Stormwater Engineer

Review standards and policies that ensure

structural BMPs will be in conformance with

the state’s Stormwater Management

Design Manual

Review local standards to remain in compliance

with the NC DEQ BMP Manual. Additional

measures and techniques may be added to the

local ordinance as they are investigated.

X X X X X Stormwater Engineer

City Planner

Review maintenance standards and

inspection program to ensure that on-site

controls continue to function as designed.

Review the maintenance standards and

inspection program for local on-site controls.

X X Stormwater Engineer

City Planner

Maintain the education program created for

land developers and the public.

Maintain the education program created for land

developers and the public detailed in other

BMP’s. Report annually on progress made.

X X Stormwater Engineer

City Public Works Director

City Planner

Coordinate with the county health

department on developing and

implementing an oversight program to

minimize the potential for fecal coliform

contamination by ensuring proper operation

and maintenance of on-site wastewater

treatment systems.

Coordinate with county health department. Report

Annually on progress made.

X X X X Stormwater Engineer

City Planner

City Public Works Director

Green Infrastructure Practices and

Strategies will be encouraged.

Green Infrastructure Practices and Strategies will

be encouraged and existing standards may be

eased to encourage green projects.

X Stormwater Engineer

City Planner

Inspections and long-term maintenance of

Stormwater Control Measures (SCMs)

Maintain an inspection and maintenance plan for

SCM’s. Annual SCM Inspections performed by a

qualified professional. SCM maintenance and

inspections will be reviewed by the town during

the permit cycle.

X X X X X City Engineer

City Planner

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 22

7.5.2 Stormwater Management Options

The existing land usage ordinance has a post-construction stormwater runoff

management program for new development and redevelopment projects that

disturb greater than, or equal to, one acre. This ordinance may be revised prior to

the end of year 3 of the permit to incorporate Low Impact Development (LID)

provisions and Nutrient Reduction limits as defined in the Jordan Lake Nutrient

Reduction Strategy will be adopted within the timeline established by NC Session

Laws and NC DWQ Regulations.

7.5.3 Non-Structural BMP’s

The receiving streams in the City’s watershed are classified as Nutrient Sensitive

Waters; therefore the post construction ordinance ensures that best management

practices for reducing nutrient loading are implemented. In addition, a nutrient

application (both inorganic fertilizer and organic nutrients) management program

has been developed and is included in the stormwater management program.

7.5.4 Structural BMPs

The City has certified its BMP manual as equal to the NC DWQ BMP Manual. The

City reviews structural BMP’s based on the NC DWQ BMP Manual and will

continue to do so in the future. The City may investigate additional qualified BMP’s

in the future. These additional techniques are to be evaluated based upon field

testing and evaluation by the City’s Engineer.

7.5.5 Regulatory Mechanism

The City’s Post-Construction Ordinance establishes the City’s ability to regulate

new development for water quality compliance.

7.5.6 Operation and Maintenance

The City’s Post-Construction Ordinance establishes the City’s ability to regulate

new development for water quality compliance. The ordinance includes guidelines

for delegating routine and non-routine maintenance responsibilities to ensure

access for inspections, and providing a mechanism for enforcement.

The City will require annual submissions of BMP inspection reports and the City

will inspect each BMP during each permit cycle.

7.5.7 Education

An education process for developers and citizens about new development with

respect to stormwater and water quality has been established and is ongoing.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 23

7.5.8 Decision Process

The post-construction stormwater management program ensures that controls are

in place that will prevent or minimize water quality impacts from new development

and redevelopment projects. These controls include post-construction ordinance

to address post-construction runoff control from new development and

redevelopment projects and ensure adequate long-term operation and

maintenance of BMPs. Future revisions to this ordinance will be intended to

enhance water quality.

7.5.9 Evaluation

The post-construction site management for new and re-development activities

program will be evaluated based on how each individual BMP is meeting its

measurable goal at the end of each reporting period. Changes will be considered

for any BMPs that are not meeting the measurable goals.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 24

7.6 POLLUTION PREVENTION/GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS

7.6.1 BMP Summary Table

BMP Measurable Goals

Responsible Position/Party

Maintain Inventory and O&M Manual

of Municipal Facilities and Operations

Maintain, update, inspect annually all Municipal

Facilities and update as needed Operation and

Maintenance Manual for every facility and operation.

X X X X X Public Works Director

Stormwater Engineer

Spill Response Procedures Maintain or create Spill Response Procedures X X X X X Public Works Director

Streets, Roads, and Public Parking

Lots Maintenance Program

Maintain Implementation of BMP’s. Evaluate Annually

for cost and effectiveness.

X X X X X Stormwater Engineer

Public Works Director

O&M for municipally owned or

maintained catch basins and

conveyance systems

Continue implementation of O&M Program for the

MS4, including catch basins and conveyance systems.

Reassess program annually.

X X X X X Stormwater Engineer

Public Works Director

O&M for municipally-owned or

maintained structural stormwater

controls

Continue to implement/and maintain the O&M Program

for municipally-owned or maintained structural

stormwater controls. Document inspections and

maintenance

X X X X X Stormwater Engineer

Public Works Director

Pesticide, Herbicide and Fertilizer

Application Management

Ensure municipal employees and contractors are

properly trained and all permits, certifications, and

other measures for applicators are followed.

X X X X X Public Works Director

Staff Training Maintain an employee training program for employees

involved in pollution prevention and good

housekeeping practices.

X X X X X Stormwater Engineer

Public Works Director

Vehicle Washing Maintain measures to minimize or prevent

contamination of stormwater runoff from all areas used

for vehicle and equipment cleaning.

X X X X X Stormwater Engineer

Public Works Director

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 25

7.6.2 Affected Operations

The City of Graham operates a municipal building that serves as a City hall and fire station, a police station, a Public Works

vehicle and equipment storage yard, and a maintenance facility for the Parks & Recreation Department. All vehicles,

equipment, and materials at the storage yard and Park maintenance facility are stored in covered buildings. There are no

floor drains in any of the buildings at these two facilities.

7.6.3 Training

Training materials have been developed on pollution prevention for public facilities, using similar materials as will be used

in the public outreach program. All employees will be educated on the need for controls to protect stormwater from exposure

to potential pollutants. This training will also serve as the training requirement for public employees as specified in the

outreach component of the Illicit Discharge section of this program.

All public employees involved in vehicle, open space, or building maintenance operations will be provided training in BMPs,

the processes and materials they are working with, safety hazards, practices for preventing discharges, and procedures

for responding quickly and properly to toxic and hazardous material incidents.

All public employees involved in stormwater drainage system maintenance will be specifically trained in the disposal of

floatables, grit, sediment, and other pollutants removed from the system. Additional training, or certification, will be provided

to employees that manage and apply chemicals for control of dust, pests, vermin, and weeds and/or to enhance the growth

or condition of public urban landscape and recreation facilities. Training will target the safe and effective application, storage

and disposal of chemicals used.

7.6.4 Maintenance and Inspections

A preventive maintenance program has been developed that includes routine inspections of catch basins and other

stormwater systems for the municipal building and vehicle storage yard. The objective of the inspections is to reduce

pollutant loading from municipal sites. Inspections include noting any problems or issues that may have an impact on

stormwater quality, and any corrective actions needed. Schedules, procedures, and a record-keeping system are used to

schedule and document inspections.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 26

7.6.5 Vehicular Operations

All vehicles, equipment, and associated material at both the Public Works and Parks & Rec. facilities are stored inside

buildings. The Public Works vehicles (pickup and dump trucks) are currently washed outside, with the untreated wash

water discharging into a nearby drainage ditch. Washing of these vehicles at another location has been investigated but

is non-cost effective and pollution runoff is minimized by runoff not going across impervious areas and not going directly

into surface waters. Minor vehicle and equipment maintenance take place at these facilities.

7.6.6 Waste Disposal

Garbage, recyclables, and heavy trash collection are contracted out to private companies.

7.6.7 Flood Management Projects

Future flood management projects will be reviewed from a water quality standpoint.

7.6.8 Decision Process

The most effective and practical BMPs for minimizing stormwater pollution were selected for this program.

7.6.9 Evaluation

The pollution prevention/good housekeeping for municipal operations program will be evaluated based on how each

individual BMP is meeting its measurable goal at the end of each reporting period. Changes will be considered for any

BMPs that are not meeting the measurable goals.

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 27

7.7 TOTAL MAXIMUM DAILY LOADS (TMDL)

7.7.1 BMP Summary Table

BMP Measurable Goals

Responsible Position/Party

Establish if a TMDL exists on a

receiving water of the MS4

Verify TMDL’s annually. X X X X X Stormwater Engineer

Identify, Describe, and Map

watershed, outfalls, and streams.

Identify watershed WLA for stormwater, describe

watershed, map watershed, identify location of major

outfalls in watershed, identify impaired streams in

watershed, and identify schedule to discover and

locate other possible contributing sources.

X Stormwater Engineer

Existing Measures Create Water Quality Recovery Program. X Stormwater Engineer

Monitoring Plan Create and submit to NC DWQ a monitoring program

for each pollutant of concern in the TMDL.

X Stormwater Engineer

Additional Measures Additional measures that improve water quality may be

started as needed.

X X X Stormwater Engineer

Implementation Plan Determine final implementation schedule, including

when in the permit additional items will be

implemented.

X Stormwater Engineer

Incremental Success Determine if and/or how incremental success will be

measured.

X Stormwater Engineer

Annual Assessment Submit Annual Report on program to DWQ X X X X X Stormwater Engineer

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT

ITY OF GRAHAM

Page 28

7.7.2 Determination of TMDL’s

A TMDL on a receiving water with a stormwater Waste Load Allocation (WLA)

will trigger the need for compliance with this section of the CSWMP. A TMDL with

no WLA will not require a Water Quality Recovery Plan, but rather the need to

evaluate existing strategies and if any can be tailored or expanded to improve the

water quality in the TMDL watershed.

7.7.3 Establishing a Water Quality Recovery Plan

Based on the above schedule the City of Graham would begin creating a Water

Quality Recovery Plan (WQRP) within 12 months of establishment of the TMDL,

would have evaluated existing measures within 24 months, developed a

monitoring plan within 36 months, and would be implementing or have planned for

implementation within 48 months. The WQRP would be submitted and approved

by NC DWQ and EPA.

7.7.4 Decision Process

TMDL planning and implementation will be done in an effort to improve water

quality and with the approval of NC DWQ staff.

7.7.5 Evaluation

Progress toward restoring water quality standards will be difficult to determine and

most evaluation tools will be based upon programs rather than through water

quality monitoring or water quality improvements. While the goal of a WQRP is to

improve water quality standards, the NPDES MS4 permit obligation is to reduce

non-point source pollutant loading to the maximum extent practicable (MEP). The

MS4 is not required to meet water quality standards. Evaluation of successful

techniques will be evaluated over time, probably multiple permit cycles.