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HomeMy WebLinkAboutNCS000605_Hudson 2021 APPROVED SWMP_20210511Final Stormwater Management Plan Town of Hudson NCS000605 April 19, 2021 � ��D;..� E Q I&rrkv�n.ntsi 0us;�ly APPROVED fIj. ' 1" May 11, 2021 Jeanette Poive11 MS4 Progi u Coordinator Table of Contents PART1: INTRODUCTION............................................................................................ PART 2: CERTIFICATION .............................................. PART 3: MS4INFORMATION..................................................................................................................3 3.1 Permitted MS4 Area .......................... .............................. 3.2 Existing 5 MS4 Mapping ...................... 3.3 Receiving Waters.......................................................................................................................... 3.4 .......................................................................................I........ MS4lnterconnection.....................5 .).5 Total Maximum Daily Loads (TMDLs) .............. ..................6 ........ 3.6 Endangered and Threatened Species and Critical Habitat .................................... .... . 7 3.7 Industrial Facility Discharges............................................................................ 8 3.8 Non-StormwaterDischarges .........................................................................................................9 3.9 Target Pollutants and Sources................................................................................................... PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION...................................13 4.1 Organizational Structure .................................................... ..................................................... ....I 4.2 Program Funding and Budget.....................................................................................................15 4.3 Shared Responsibility.............................................................................................................4...15 4A Co-Pernuttees.........................................................................................................................0....17 4.5 Measurable Goals for Program Administration...................................................... PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ................... INVOLVEMENT AND PARTICIPATION PROGRAM..•��• �•� � �•-•� ................ 28 PART 6: PUBLIC PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM ........................ . ..... 33 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM......... """"' ...43 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ... •-• •..••57 List of Tables Table 1: Summary of MS4 Mapping Table 2: Summary of MS4 Receiving Waters Table 3: Summary of Approved TMDLs es/Babitat Impacted by Surface Water Quality Table 4: Summary of Federally Listed Speci Table 5: NPDES Stormwater Permitted Industrial Facilities Table 6: Non-Stormwater Discharges Table 7: Summary of Target Pollutants and Sources Table 8: Summary of Responsible Parties Table 9: Shared Responsibilities Table 10: Co-Permittee Contact Information Table 11: Program Administration BMPs Table 12: Summary of Target Pollutants & Audiences Table 13: Public Education and Outreach BMPs Table 14: Public Involvement and Participation BMPs Table 15: Illicit Discharge Detection and Elimination BfPConstruction Site Runoff Control Program Table 16: Qualifying Alternative Program Components Table 17: Construction Site Runoff Control BMPs Table 18: Qualifying Alternative Progr am(s) for Post -Construction Site Runoff Control Program f Existing Post -Construction Program PART lc INTRODUCTION The purpose of this Strut Management Plan (SWMP) is to establish and define the means by which the Town of Hudson will comply with its National Pollutant Discbarg applicable provisions of the Cstem rlean Water Municipal Separate Storm Sewer System (MS4) Permit and the P Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent practicable. on will ntal This SWMP identifies enforce, evaluate and reporto the North Caroli ecific elements and minimum measures a D MLR)ent of order tthe Town of o com comply develop, imp Minerals and Land Resources (DEMLR) n order to comply with Quality (NCDEQ) Division of Energy, This ermit covers activities associated with the MS4 Perm t number NCS000605, as issued by NCDEQ. P the discharge of stormwater from the MS4 as owned and operated by the Town of Hudson and located irements within the corporate limits of the Town of Hudson. In preparing this SWMP, the Town of Hudson has evaluated its MS4 andne o dseaddresglocal water develop a comprehensive 5-year SWMP that will meet the c mm m 'with the perm t. The SWMP will quality issues and provide the min mum measures necessary P y be evaluated and updated annually to ensure that the elements and minimum measures it contains continue to adequately provide for pemrit compliance and the community's needs. Once the SWMP is approved by NCDEQ, all provisions contained and referenced n th s SWMP, along with any approved modifications of thJ W hD s o th approved SWMP wrll requ re Teout and come bm ttal, enforceable parts of the perm t. Any ng on the nature review and approval by NCDEQ, and may require a new public comment period dependi of the changes. pINALNCS000605 SWMP Town of Hudson April 19, 2021 Page 1 PART 2: CERTIFICATION By my signature below I hereby certify, under penalty of law, that this document and all attachments were ystern de sied to prepared under my direction andsupervision in accordance with a s or the information submitted, Ba se, on my inquiry assure the person or personnel properly gather reformat h submitted thesystem, to the best those perandand belief, trusons directly e, accurate, cur te, andgcohmpletermation, the nformation, including the possibility of I am aware that there are significant penalties for submitting false i fines and imprisonment for knowing violations. I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4 Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit compliance and enforcement authority. ® I am a principal executive officer or ranking elected official. ❑ 1 am a duly authorized representative and have attached the authorization made in writing by a principal executive officer or ranking elected official which specifies me as: erall responsibility for stormwater matters. ❑ A specific individual having ov ❑ A specific position having overall responsibility for stormwater matters. FINALNCS000605 SWMP Town of Hudson April 19, 2021 Page 2 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This Stmmwater Management Plan (SWMP) applies throughout the corporate limits of the Town of Hudson, including g all regulated activities associated with the discharge of stormwater from the MS4. The ma "in `udin the corporate limits of Town of Hudson as of the date of this document. FINAL NCTo n of H dson April 19, 2021 Page 3 3.2 Existing MS4 Mapping The current MS4 mapping includes outfalls located within the To flow wn c directiorn, coverts ditchesginlet n will be adding the following elements to the map: s p catch basins, manholes outfallL sizes and Condit ons (Reference BMP 20). The Town oer the detnution provided below. The Town will be ver fy ng all f Hudson has a historic count of 82 outfalls per the GIS layer crea e ; certain that all of these are majorp let on of BMP 20. elements as mentioned above in the comp FInAI-NCTo nofAudso�n April 19, 2021 page 4 Table 1: Summary of MS4 Mapping percent of MS4 Area Mapped 10 Outfalls* Mapped 82 total No. of Major oint where the MS4 discharges from a pipe or other conveyance uire a ditch) directly *An out is a p ou alls are required to be mapped to meet permit req wind for tindu major al Zoned into surface waters. Major outfall is a 36-inch diameter pipe or dischaarea m 2 acaes�ge area > 50-acres; areas a 12-inch diametw pipe or a drainage 3.3 Receiving wags licable water quality standards listed below are compiled The Town of Hudson MS4 is located within the Catawba River Basin and d scharges d rectly rnto receiving waters as listed in Table 2 below. App from the following NCDBQ sources: e Wsterbody Classification Ma o Im>aired Waters and TM nL6 a� List o Most recent NCDEQ Table 2: Summary of MS4 Receiving W je Number tyiasaiu4�=�� 1.5 .,0�(d) Creek (I1-55- Impairment-Benthos (0.5)) and (11-55- (1.5)) nwder Creek (11-55-2 C 3.4 MS4lnterconnection The Town of Hudson MS4 is intercoected with another regulated er ed. The Town of Hudsonowill be from the Town of Lenoir MS4. The number of interconnections entering the Town of Hudson n will b (reference the Town of Lenoir is unknown due to the storm sewer not being mapp in the future mapping the storm sewer lines and water flow to help determine interconnectivity BMP 20) stormwater from The Town of Hudson MS4 is interconnected with another regulated MS4 and directlyThe Town will be therTown of Hudson MS4 is unknowns MS4, toduet the to The 'lumber sewer not being mappreceiv ng sewer lines and flow direction in the future (reference BMP 20) mapping the storm FINAL NCSo000605 n of Hudson April 19,2021 Page 5 Currently, a limited amount of data is available. Field staff will collect further data using a GIS mapping Mappinga existing plans or blue p lication off of field techn conditions. Staff will develop data recording, and pre - application li locate flow direction, inverts, ditches, inlets, catch basins, manholes outfall, sizes an velo from the Town of Hudson. The MS4 does nterconnect with the statewide NCDOT MS4 and includes: ction is receiving stoimwater from the NCDOT MS4. The number of a. The interconne interconnections is uilrno b The interconnection is not discharging st"awater nto the NCDOT MS4. The number of interconnections is unknown c. ing does not identify interconnections with the NCDOT The Town of Hudson MS4 mapp MS4. of Hudson MS4 mapping does include NCDOT MS4 outfalls. d. The Town 3.5 Total Maximum Daily Loads (TMDLs) the map s listed n Table 3 below have been approved within the MS4 area, as determ ned by The TMDLO to any watershed and list provided on the NODE Model'uis & A sessment Unit web a e. The Allocation (WLtable also indicates am ormm whether the approved TMDL has a spe MS4, and ter whetheaa Water Quality program directly receiving discharges from the permitted has been implemented to address the WLA. Outreach education and stream cleanup helps with the reduction of waste load allocation within approved TIvIDL rmmiciPalit es. FINALNCTo wofHudsorr April N, 2021 Page 6 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endangered species and/or cria itical habd andThretare identified within the cul regulated MS4 urbanized area. Based upon a review Map 1 fe eCl- e, the species listed in Table 4 have S ecies of Concern b Count for North Carol Ma and Listed sLAC ecies believe io or known to in North Carolina man as provided by the U.S. Fish_ li — by the quality of surface waters with n their habitat. the potential o occur cur within the regulated MS4 Of those species listed, Table 4 summarizes s the species that may be significantly impacted Water Quality Table 4: Potential Federally Listed Species/Habitat Impacted by Surface s Pcies Group Federal L �taucv„,yam �_-. - Ilyin squirrel T coloratus - - eared Vertebrate Myotisseptentrionalis barthernlong E bat Vertebrate Corynorhinais Virg�iabig-eared townsendii a �hus Edmons's Jnaxc�aia - Invertebrate ARS margarita Margarita R ver skimmer E a Spruce -fir moss Invertebrate spider Vascular Plant T naniflora Ded warfDwarf� — Partleaf ed purpurea var 3.7 Industrial Facility Discharges The Town of Hudson MS4 jurisdictional area includes the following industrial facilities which hold ed from the NCDE NPDES Industrial Stormwater Permits, as determ nMa s & Perm' Data web a Te• F INAL NCTo on of Hudson April 19, 2u2 Page 7 Table 5: NPDES Stormwater Permitted Industrial Facilities g68 Non-Stormwater Discharges es have been evaluated by the Town of Hudson as The water quality mipacts ofnon-Stormwater discharg summarized in Table 6 below. The unperomted non-Stormwater flows listed n incidental do not significantly impact water quality. The Town of Hudson has evaluate residential and charity car washing and street washill for possible significant water qualityimpacts. Street washing discharges are addressed under the Pavement Management Program in Part controlled by the 10 of this SWMP. The Division has not required that other non-stormwater flows be specifically Town of Hudson. e directly that does not contain detergents or does not discharge directly do Wash water associated with car washing es ofnon-Stormwater discharges the Town of Hudson to determine of the below into the MS4 is considered incidental. However, these p contain detergents have been evaluated by Town of Hudson will address the possibility as outlined in Part 5, Sig f cantly impact water quality. of good mentioned water quality impacts through public education and good housekeeping, the g, BMP 3.7, and Part 10 BMP 46-49, 50, 54, 55, 57, 58 and 62 with a focus on the tra rung housekeeping practices, FINALNCTo 06ofHuds n April 19, 2021 Page 8 3.9 Target Pollutants and Sources In addition to those target pollutants identified above, the Town of Hudson is not aware of other significant water quality issues within the permitted MS4 area. ollutants identified rani gand ideout ntifies firs the assooc 3 of this a edhe Table 7 below summarizes eted audienhe water ces attributed to each p likely activities/sources/tang acts. SWMP program(s) that address. In addition, the Town of Hudson has evaluated schools, homeowners an businesses as target audiences that are likely to have significant stormwater found to be concerns within Within the table below the following target pollutants have been commonly the community, Litter: Illegal dumping has occurred and been noted by code enforcement officers within the Town. Cases of both illegal construction waste dumping and general residential or school dumping have been s that damage the pipelines leading back to the noted by code enforcement officers. This litter poses a threat to both our water bodies and the MS components uses a threat to groundwater if chemical leaching or breakdown of infrastructure, as the fitter can create clogs and backups road side stream. Some litter even. p of the litter. The dumping has been found typically into heavy metals occurs due to weathering but also in secluded urban areas. Sediment: Previous installed erosion control measure have been removed or fallen . Correctly ith len or in sediment buildup is largely attributed to mismanaged construction sites code enforcement officers sediment fences. It has been noticed n both reports from citizens and y work. This onto down slope private properties, and insome emoove there are several cases of construction sites not maintaining the r erosion control fences mg as the sediment is limiting the drains ability down for a has led to sediment buildup near storm drains, causing water to build up in nearby properties and had the issue solved but even being runoff. In all cases code enforcement has respondedquires. short time can prove to have significant effects. Erosion control fences are required for sediment control permits during construction by the DEQ throughout the entire construction p Gray Water: Straight piping washing machines out of the house Residents have noted a few homes have had their washing machines straight -piped out of their homes by creating makeshift piping using water hoses exit at windows. Homes are to be connected to the appropriate sewer system. This proves to be a source of deteergdentsunoap� entering hes allow for soaps or cleaned in the correct areas (such as vegetated residential neighborhoods. In addition: residential, charity, This allows for toxic contaminants to enter our waxes to enter the storm drain when vehicles are not being patches or rvia thareas e stormdraindra n system t do not have rm drains). waterway FINAL NCS0o0605 of Hudson April 19, 2021 Page 9 Fats Oils and Geese traps ase: He for 3alth DP Department has priate removal* noted several cases where restaurants do not empty or own/rent grease or even owning, The Health Dep in the grease or all the artment has reported several restaurants in Hudson not maintainmg, issues. grease traps. This has led to cases of the restaurants either illegally dmnen g� waste contributes to this grease to drip onto nearby mpermeable surface — which would ease w th filly lead to water quality out the grease but it also can impair water Overflow from a lack of maintenance or throwmge poses a physical risk problem. This is a health violet on since the grease down the storm drain. bodies with an influx of water insoluble grease going labeled or stored Chemicals: Totes have been noted in industrial areas not properly own/unmarked chemicals are Town staff, along with some citizens have reported that containers of unkn to otern al soil and water cone T wn has o�dxthat the incorrect spill unlabeled in select industrial sites, leading phe containers correctly, cleanup procedure. In addition to not labeling to minimize risk to the water bodies from seepage, containers are not being correctly stored n a way damage to the containers, or spills. Animal Operations: A challenge to ensuring water quality for several factors. operations are agriculture operations that raise cows, pigs, chickens; or other livestock as a byproducts of the animal, the latter being more problematic as the excess Animal op h oxia in the water body. In a similar product, be it from meat or hic s with nutrients will lead to eutrophicat on which can eventually causing YP vein, ag 46 streams are/were imp acted by fecal ricultural innoff often caries excess fertilizer which also will cause eutr pollutant it is hardhication in to locate effects. Within the Catawba R ver Basin roughly Dint source p that makes its cascading fisted on the 303(d) list. As this is a non-p coliform, with 10 being � agricultural hohowever to occur. Roughly 20°/ of land use within the basin is ag the exact source of this runoff, however n much of the watershed there is agriculture zonmg it likely for these types of impairments Underground storage tanks: Storage devices installed below ground that contain hazardous materials/waste, gasoline, fuels such as pr°Pa°a= industrial them cals/oils, and most °u t be welln connected to the sanitary sewer. Any underground storagecan cause These tanks can contain g g. The leaks waste in areas not directly d due to ground, harming the soil, groundwater/water table, maintainedlmorrhored, and correctly i s leak into the gr risk of them the so tank whatever chemical the tank is stor ng fed from groundwater. If a fuel or industrial chemical and is to toxic soil, contam nated gr processes and even surface waters will that are being leaking, If a septic tank is leaking, it can overwhelm the natural pathogens the chemical will leach into the soil —leading n oundwatex, or allowing P possibly impairing a stream water body. streams Of the soil (infiltration) leading to notr ent overload fecal coliform impaired streams listed can have to enter, increasing the risk of disease. The 10 303(d) some attribution to septic tank leakage. uall varied number of effects Illicit discharges: Originate from a variety of sources, with an eq Y dependent on the chemical that is released. FtNALNCTo 0605 of Hudson April 19, 2021 page 10 Typically, illicit discharges come from businesses, residents or municipal facilities who dump chem cals solut ons, pa nts, metals, etc. into storm drams either incidentally due to a lack of IDDE education or general carelessness. These chemicals can vary g streams impaired from causes related to generated greatly and call include grease, oils, chemicals, cleaning This is a recognized problem as we have several 303(d) substances or attributions given to unclean discharges into the streams - e addition to reports g by the municipality. Many of the 303(d) benthI impaired streams call it iscattrareas to IDDE issues, but they are often from inexact non -point sources that are attributed to illicit discharges es, or municipal employees dump waste randomly in Illegal dumping: When residents, business non-permitted dumping areas. This waste can widely vary, causing a variety of problems. For examPle, citizens dumping televisions on the side of the road to avals or chemicals inside th oid dumping fees, which allows for the an be a case of businesses damping each lead and other metals). n it, or residuals of the out as stormwater passes it (mercury, h the waste, either carry g aders dumping sediment into areas without the correct waste in watershed areas where runoff passes throug waste into water bodies. It can also be a case of gr g4 system. che ents, or debris entering the stream/M alaote into preca odies. The debris and chemicals accumulate over time and lead to system. mca tion impairments, PH issues, turbidity mpa rm Improper disposal of waste: e waste, to problematic because it allows chemie les not giving atcarlbattery to the Improper disposal of waste is p be hard to track. For examp enter the environment m ways that may acid and lead to enter the soil which managers and is correct waste management facility can allow for battery municipal waste . Other drains/collects in the groundwater. This problem has been noticed by chemicals from batteries leaching into difficult to track as often the improper disposal waste is mixed in with the standard refuse. O er examples include grease going down sinks clogging MS4 systems, the groundwater, oil from oil changes not going to the correct facility, etc. Table 7: Summary of Target Pollutants and Sources Public Education & Ur Residents, Businesses, Schools public Partici ation Public Education & 01 Construction Activity Construction Program Sediment Gray water Oils and Grease Businesses (Restaurants) public Education & Uutreacn Industrial, Business and Resident al publicEducation& Outreach Operations a FINAL NCTo On of Hudson April 19, 2021 Page 11 Storage Tanks Business and Illegal Dumping ana mproper Disposal of Waste Gene c, Businesses, MunicipalEmployees General Public, Businesses, Municipal Employees Illicit Discharge Public Education & Outreach Illicit Discharge Public Education & Outreach FHeALNCS000605 SWMP Town of Hudson April 19, 2021 Page 12 pART 4: STORMS ATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure WpCOG) to coordinate Best Management Practices to The Town of Hudson has contracted W estern Piedmont Council of Goven monram the Town of Hudson Stor nwater Management Plan efforts, to ensure theTownisfacilitating the program protect water quality- While WpCOG will be the primary ort actions to WPCOG. The fol' ement. Each staff will be training to handle internal procedures and rep th rmwater Organizational chart is In down by the six elements associate mlanageo and then on to the Stormwater of the positions under the elements will report back to the primary Program Administrator. of Responsible Parties Table 8: Summary Responsible SR MP Component Town Manage Stormwater Program Administration SWMP Management planner/Natural Resources Rebecca own FINALNCS000605 SWh'lp Town of Hudson April 19, 2021 Page li WpCOG Senior Johnny Wear - Public Education & planner/Natural Outreach Resources WPCOG Administrator Johnny Wear WPCOG Senior Public Involvement & Planner/Natural Participation Resources WPCOG Administrator Todd Justice WPCOG Code Illicit Discharge Enforcement Officer Detection & NCDEQ — Asheville Elimination N/A N/A Regional Office Construction Site WpCOG Runoff Control Jack Cline WPCOG Stormwater Post -Construction Administrator Stormwater WPCOG Management Johnny Wear WPCOG Senior Pollution planner/Natural Prevention/Good Resources Housekeeping for Administrator Operations WPCOG Municipal Op WPCOG Stormwater Jack Cline Municipal Facilities Administrator Operation & WPCOG, Maintenance Program Jack Cline; TBD Volunteer/Town Fire Stormwater Department, if Spill Response Program Administrator and a licable Volunteer Emergency Services To of Hudson Public Town of Hudson Public TBD Works Department MS4 Operation & Works Operator Maintenance Program Jack Cline Town of Hudson Public Town of Hudson Public TBD; Works Department and Municipal SCM Works Operator and WPCOG Operation & Stormwater Maintenance Program Administrator Jack Cline Town of Huardstment and Town OfHudsonPublic TBD> WoxksDep Pesticide, Herbicide & Works Operator and WPCOG Fertilizer Management WPC OGStormwatex Town of Hudson Publi Program Adm n strator Department Town ofHudson public TBD Woks Vehicle & Equipment Works Operator Cleaning Program FINALNcsoOO605 of Hudso April 19,2021 Page 14 Woo Huosor Pavement; nagement Woik, operator Program in of Ijudson Public Works Department 4.2 Program Funding and Budget and staffing to adequate funding 1 with the requirements of the NPDES In accordance with the issued perm t, the Town of Hudson shall With l mplement and manage the provisions of the S3 and comp y and compliance fee, which is billed by DE et includes the permit administering eaz of the permit cycle will will used to MS4 Permit. The budg emit mandates, the first y din mechanism will be Due to the increase NPDES p needs. The fun g program will annnallysis to determine how the stormwater determine a base line for �letion oof atfisoal gap anal}dmg analyzed through the comp obtained. be implemented and funding adopted, and ents for the following services: Currently, the Town of Hudson, has a two year °Ontract (which will need to be modified, Public Involvement and Part cipat on Progra ,Illicit Discharge signed every two years) with R estern Piedmont Council of Governor d pollution Public Education and O Pr gPr a ' ear Period (years 1 Post-ConstThe1oll Site ccurrent cRontrac�amounol P oxgthe 2-y Detection and Eliminationprograms• responsible for the cost of the prevention and Good Housekycle) i $33 772.00. The Town will be ermit Cycle) aid to the state. Any fees charged to the development community and 2 of the NPDES p wh ah is to be p the Town May NPDES permit renewal, and other associated fees will help offset cost. The Town y t ections, Plan Review, implemented; these fees would be collected by for BMP Insp fees should be imp ort the stormwater program determine that storm bills. The goal would be for the fiords collecte to sup funding will be tax through or utility and other water quality efforts. Revenue versus through mapping outfalls, stream repanrs, reviewed each year to determine needed changes• eaz contract, pr or to the last month, a Should the Town two y erniit and stormwater Management Plan would need to occur, The of Hudson choose notto renew the existing eft cycle. NPDES p out the 5 year NPDES p revision to the existing uired to fully carry Town of Hudson would be req 4.3 Shared Responsibility witli �,TpCOG (referred to as um control measures, which areas str regent as the Beginning July 20195 the Town of Hudson will share the responsibility, entity), to implement the following minim' be subj ect to enforcement NPDES MS4 Permit requirement. The Town °at on and may ors responsible or correspondingfails to perform the permit obligation permit obligation. Table 9 nor the other entity fully performs the P compliance if the other entity action, if neither the Town al Hudsonponsibilities for each program. below summarizes individual responsibilities Table 9: Shared ResponsibilrtieT F7NALNCS000605 SWMP Town of Hudson April 19,2021 page 15 3ener—al eqR u rements Public Education and Outreach Public Involvement and Participation Program IIlicitD� h gr eac Detect and Elimination Progra �,..,�r.,ction Site Runc Pollutio on and Good Housekeeping Pro ams Total Maximum DailY L Stormwater t azui�,o.Lr Stormwater Partnership Stormwater Partnership i Stormwater Partners"IF Stormwater raz�u�i ��ur Stormwater Partnership Y Y GI FihALNCS000605 SWMP Town of Hudson April 19, 2021 page 16 4A CO- Permittees eruuL number There are no other entities applying for co-permittee status under the NPDES MS4 p NCS000605 for the Town of Hudson. 4.5 Measurable Goals for Program Administration Referencing, MS4 Inspection Report for the Town ofHudson - Program Implementation, on, Documentation & Assessment, Permit Citation - II.A.2. Stormwater Plan Implementation &Evaluation, mwat Keeping the Stormwater Plan UP to Date, ILA.4. Availability of the Stormwater Plan RA.S. Stormwand ater Plan procedures for doing so. In order to meet the State Modifications and ILA.7 Written Procedures; the Town has not evaluated the performance conents will be effectiveness of the program and had not develop any p Management Plan: SWMP, requirements for this section, a self -assessment and the effectiveness of the Man Permit Year One of the will be adopted during ear O completed annually. Written procedures, otherwise known as, Stormwater snag has been drafted, but not adopted at this time. The he Mp SW it- NPDES permit cycle following the acceptance of the SWMP and issuance of the NPDES p MS4 Insp for the Town of Hudson - Program Implementation, Documentation & of Lenoir on the Town' City s behalf ection Report llicit d scharge compla nts and enforcement actions; however, Assessment, Permit Citation - IILA. Pr°gram Documentation; The maintained some documentation regarding to the Town's Stormwater program (e.g., no there was an overall lack of documentation relating documentation for inspectrons, maintenance activities, or educational programs). MS4 Inspection Report for the Town of Hudson -Program Implementation, Documentation & trol Assessment, Permit Citation - III.B. Annual Report Subm ttal: The latest MS4 annuai report submittedurn con year, The report ncluded a brief description °f ti ecif e miles ones for was for the 2014-2015 reporting y report lacked deta l regazding sp period. Instead, or what was accomplished during the reporting measures and initiative at the time. However, e rep lementation, which largely had not yet been the measures, overall plan accountability, ro am imp the report described plans for future MS4 p gr implemented. Further, the 2014-2015 report did not include a fiscal analysis (Permit Citation - � o the Management Program using Public Education &Outreach, Public The Town of Hudson will manage and report the following Best Management Practices (BMP ) administration of the Stor nwatex Detection &Elimination, Post -Construction Site Runoff Involvement & Participation, Illicit Discharge Control, and Pollution Prevention & Good Housekeeping. I Annual Self -Assessment fi'INALNC�0wOnofH don April 19, 2021 Page 17 Perform an annua, ��u�-•-- gprAP implementation, suitability of SWAP proposed commitments and any utilizing changes to the SWMP utixo the NCDEQ Annual Self- 1. out the Annual al Self- APermit Years l-4 submit t Assessment to NCDEQ prior to August 31 each year. Lcation T ically 1. Yesmo 2 permit Renewal App 1. TBD — TP 1, participate in an Permit Year 4 Audit stormwater program compliance NPDES MS4 Permit implementation for comp Compliance Audit, as with the permit and approved scheduled and performed SKIMP, and utilize the results to b EPA or NCDE 2 Permit Year 5 2. Yes/No/Part�al prepare and submit a permit 2. Self -audit and renewal application package. document any stormwater program components not audited by EPA or NCDEQ Audit Utilizing the DEQ Template. Submit Self - Audit to DEMLR (required component of permit renewal a lication acka e 3. Date of permit renewal 3. Certify the stormwater 3. Permit Year 5 application submittal Permit renewal application (permit renewal application form, Self -Audit, and Draft SWMp for the next 5-year permit cycle) and submit to NCDEQ at least 180 days prior to permit ex nation. FIN AL NCTo n of Hudson April 19, L" Page 18 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM am to distribute educational The Town of Hudson will implement a Public Educat on and Outreach program acts of storm water materials to the common or conduct equivalent outreach actreduct es bouth�n'orm water runoff. discharges on water bodies and steps the public can take to reduce Pollutants Target Audiences, and 11.B.2.h. Public Education and outreach issues- program- In reference to MS4 Permit Self Audit Report -Public Education and Outreach, Permit Citation II.B•_.a uiremems,11 B.2.c. oals &objectives for community public education Program Req Program: The Town of Hudson had not defined g Stormwatex impact target audiences and extend of exposure had not been recorded at and outreach events. Part 3.9 of this S which will be addressed by n Tab12 below. in addition, the Town of The target audiences and identified pollutants listed in le the Public Education and Outreach Program, are Summarizedin associated with illicit Hudson is required to inform businesses and er disposal of waste the general public of the schar'cs, illegal dumping and improper r.,._a, ,.,, w;t1 manage, implement and report the following public education and ouuea�.� Town of tiuusui, April 19, 2021 Page 19 �tormwa«• - --- 1. Yertmr c °°" 1. Develop and Stormwater fliers will be distribute fliers at distributed to Town residences, Town events to create municipal employees, businesses, Stormwater awareness. 2 Pexnut Year 2 and industrial facilities through 2 Develop and Stormwater events. Five topics wi ill be addressed over the term of lb citdischarges. 3. Permit Year 3 the permit; general stormwater 3 Develop and awareness, illicit discharges, distribute fliers for illegal dumping, chemicals and illegal dumpin . 4. Permit Year 4 proper disposal of waste. 4. Develop and distribute fliers for chemical awareness. 5 permit Year 5 5. Develop and distribute fliers fox 4 Public Event Outreach 1. Annually Provide stormwater educational I. Staff will have a eneralpublic boo thattbeannual permit years 1-5 information to the g Hudson Butterfly at community events. Festival to disperse Stormwater outreach COVID-19 has l m ted outreach materialslawareness opportunities at public events due h the use of to their cancelation in 2020I2021. interactive educational As such, alternative ways for this games and activities. type of outreach will be necessary. Alternatives, including but not limited to, booths at farmers markets or a an th inside the library (if open) vide these opportunities while still being safe for participants. distr buted at events.. 1. Number of attenae at the outreach booth during the butterfly festival. FINAL NCS000605 SWMP Town of Hudson April 19, 2021 page 20 Youth Community Outreach alternative outreach permit Years 1-5 opportunities if the Butterfly Festival is canceled, or as an additional outreach supplement. Such opportunities include but are not limited to: an outreach booth at local Libraries, and/or an outreach booth at farmers markets, or other events if they are still available at different times 1. W YC:UU wiu act vities, and educational provide nstruct on and stormwater materials to students and youth through educational activities community groups to youth community classrooms, workshops, classrooms, community Presentations, and/or groups, workshops, hands-on activities related to community stormwater best practices s can targeted community groups include: boy scouts, gh1 scouts, 4- g clubs, school environmental programs, church/religious groups, community environmental groups. Many of the individuals in these groups will hit the same target audiences as student outreach but can be more easily 2. Utlllze uic .. _ �-�- storm stencils during outreach events to educate community members on the mpact of dumping Iinto storm drains as well as add caution vns to them 1. Permit Years 1-5 Z. Annually Permit Years 1-5 at altemative outreach booth Event/location of alternative outreach booth 1. Number of activities/events provided; Number of participants present at these events/activities. 2. Number of storm drains stenc led FINAL NCTOoOdo of H d on April 19, 2 Page 21 met—dne to the nature of Imethoc f wtation coveringpermit Yearsorgan nationswater topics to sented in digital ooms and/or ded to teachersowerPomtwill esented by ers and/or staff udenthod such as an Staff lrlw design and distrmuic new printed materials for target audiences to aid stormwater education ] .Staff wIll create 1. printed material for local government distribution address ng stormwater best pracuw�. 2. Staff will distribute 2. See B1vIP 3 pr nted materials at events,school presentations, and have them on display for public acquisition n Government buildings. The flyers will also be hosted on he, WPCOG website to enable digital access to this resource. Annual W ater Quality Conference presentations provided by teachers or staff Number of students present during the presentation 1 1, W ere new outreach materials created? Yes, No; Status. See BMP 3 IFiNAL NCTo On of Hudson April I9, 2 Page 22 Council of Govermnents and Lenoir Rhyne UrnuiversiConference Anal Water Qualmpublic to provide outreach and p Participation. Staff will conduct the annual regional conference for continued education targeting local government officials, municipal staff, local buss public. educators, and the general 1. Provide one presentation about one of the six NPDES Minimum Control Measures at each annual conference. A different MCM will be presented on each year. Permit Years 1-5 at conference.. Evaluate Pollutants Sources and Audiences 1 wally 1. - 2. Number of g' 1. Evaluate following target pollutant Evaluate the target poeuatantsfa target pollutants: violations. (litter, sediment, gray permit Years 1-5 ease, an mal operations, litter, sediment, gray oils, gr su er water, fats, oils, Were SWMP revisions underground storage tanks, P ease, animal needed to address fund sites, chemicals, illicit grease, operations, target pollutants or discharges, illegal dumping, nderground storage audiences, improper disposal of waste), tanks super fund sites, sources, and associated target chemicals, illicit audiences (residents, businesses, discharges, illegal scbools, construction industrial, dumping and improper commercial, farms, general dis osal of wasteo development community, g 2. Evaluate the 2. Annually public, and municipal employees) following target likely to have significant Permit Years 1-5 stormwater mp acts and why they audiences: residents, were selected. Th s evaluation is businesses, schools, looking at target and ences that construction act vita, are creating pollut on to allow the commercial, farms, educa Town to correctly focus cation development d efforts in those area, community, general public and municipal employees. q, Evaluate Public Education and Outreach BMPs• FINALNCTo nofHdon April 19,2021 page 23 - components of outreach through merest and feedback. 10. W ebsite 1. Did the website established 1. Maintain and update 1. Annually need revisions Yes, Maintain the already nvey the Stormwater program No; Status. website designed to co nformation on the Permit Years 1-5 program's message. The Town munici al existing P webpage will convey the website. Annually 2. Was annual self - ,importance of water quality and astaffwill assessment uploaded 2.' link to the WPCOG Stormwater m�PanOand update Permit bears 1-5 to website? Yes, no; webpage will be placed on the the WPCOG Status; Town's website. The WPCOovide Stormwater web page Stormwater webpage will p the MS4 Did links and/or list the by: posting educational resource l mks, contact information Self - compliant procedures, Stormwater Annual Self- need to be updated? Assessment, verifying regulations, stormwater permit yes, No; Status; all links and contact information and good information. information are housekeeping current/active, posting Were new/current the current year fliersfliers added to site? Yes, No; Status. The municipal Stormwater webpage will also have the current SWMp, Stormwater ordinance, and annual assessment 3. Set a hit counter order to monitor engagement. 11. Education Regarding Illicit Discharges 3 permityeazs ]-5 ;. Report the of hits. F1N EiL NCTo On of Hudson April N, 2021 Page 24 to munic P businesses, citizens and schools about the hazards associated with Illicit discharges, illegal dumping, and improper disposal of waste. employees in illic t d scharge detection A elimination. 2. Distribute material 2. See (generated from BMp 3) to target audiences I(municipal employees, schools, businesses, and cit zens). during the enforcement process. $otline This hotline will function as a way for citizens to contact the Town to report illicit discharges, stormwaterlpost construction issues, outreach questions and Iconcerns, and MS4 related concerns. 3. Continuously permit Years 1-5 1. Establish a hotline l . Permrt number for stormwater complaints and nformation. s ecific 2. perm 2.Identify p staff members who will serve as hotline Year 1 2. See 3 3. Number of citizen nteractions during enforcement. 1, Was hotline established; Yes, No; Date of establishment. 2. Was staff member identified; Yes or No. FINAL NCTo on of Hudson April M 2021 page 25 type of complaints, permit years 1-5 concerns and nfor nation related to each call. purpose of the call, type'/measure the call was about, date it occurred, and municipality of the caller will be recorded. 4 Annually, 4. Train stormwater hotline staff in general stormwater awareness, Perndt Years 1-5 complaint call Protocols and appropriate contacts for referral and typical stormwater issues. 5. Publicize contact 5. Conunuuu�.y information on the perm t Years 1-5 Town and WPCOG stormwater webpages as well as the town of Hudson facebook 13. Litter Management phone calls received by typelpurpose of call. receive training? Yes, No; Status. 5. Nmnber of nowu� calls received overall. F3NALNCTo 06ofHuds�on April 19, 2021 page 26 Create an educational outreac outreach materials wil flyer that focuses on the impacts be created and of litter on water quality, runoff quality, and how it impacts the distributed to government buildings environment as a whole. These each event materials will be distributed at and at outr cleanu Town Hall and handed out at 2. Stream p activities will be public outreach events. utilized to educate ants during participants on the Educate particip of impacts of litter on stream cleanups on the impacts Pa litter to stormwater runoff and water bodies SBMP 19 2. See BMP 19 2. ee FiNALNCS000605 SWMP Town of Hudson April19,2021 Page 27 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ram: The Town has been supportive of efforts in the un College, Early In reference to MS4 Permit Self Audit Report —Public Involvement and Participation, Permit Citation II.C.2.a.VolunteerComa tyInvolvementFrogcommunity service projects provide oppo unity for community past and plans to grow the effort in the future. The location of Caldwell Co m College High School and the Advancement Academy P form and surveyls, along with the use of the owder Creek is located on the campus of all the schools listed above. The completed within Hudson. Little Gunp e reporting swill be comp committee to gather public input. Stream clean-uP Town of Hudson will establish a hot/ ne, ttee to will be announced through social media. ex st ng WPCOG W ater Resource Cornet and public forums on an annual basis. All events, programs, implementation of a Publinot eerequirements. This SWMp identifies the minimum elements and mp Tribal and local public Program that complies with applicable State, public evolvement and participation e implement and report the following P The Town of Hudson will manage, P participation BMPs. 14. Aotline for Public Input Provide a mechanism for public input on stormwaterissues am rough the stormwater pxog util zing the stormwater hotline (BMP 12). 5 Web based form reporting Provide an onl ne form for public input and stormwater reporting via the WPCOG website. This will create an add t °nal way for 1. Stormw 1. See �BNIP 12) sball nclude a public input component and/Or record public input cornmentslconcerns. 1. Establisn a w�� based complaint/ reportinglinput form to be housed on the permit Year 1 1. See BMP 12 1, Was the omme ,�«: established? Yes, No; Status. FINAL NCS000605 SWMP Town of Hudson April 195 2021 Page 28 concerns, as weu as rav the stormwater program. i6, Social Media Ou___trea=h — on 2. Use the form to record and track responses, nputs, issues, and concerns for metre reporting. purpose of each question, report, or comment will be documented to allow for evaluation. ;. Ma nta n the web based complaint/reportinglin put form on the WPCOG website. Zvent PromotiOn Uti perm t Years 2-5 3. Connnuuu°,y, permit Years 1-5 1. Utilize the exrscmg 1. Permit questions, reports, alld comments submitted via the form. 3, Were revrsrons to the web form needed? Yes,No; Status. 1. Tot ber of posts on the Town of Hudson Facebook page related to the stormwater prow am. FJN,kLNCS000605 SWMp Town of Hudson April M 2021 page 29 Provid ae meo ah n sm for pubnc nput and participation via regional meetings on stormwater issues and the stomrwatex program. Typically, this committee is hosted by the WPCOG once a quarter. This committee also encourages municipal interconnectivity regarding water quality within the region. l , participate in quarterly Water Resource Committee meetings, which are open to the public, for discussion of water quality issues within thexegion. Topics discussed w ll be recorded for annual reporting. .Quarterly meetings 1. Number of attendees at each meeting. pe mit years 1-5 and Evaluation Annually 1. Number of surveys IS 1, Public survey 1, Create andcompleted. Provide a mechanism for public to sure s an annual t years 1-5 a survey input by creating survey too be housed on Perm engage the public and gauge the WPCOG public interest in stormwatex stormwater website issues and the stormwater once a year, open to program. The survey will be feedback for a total of taking in responses/input on the 4 weeks The survey program as a whole , covering e and BMP will also be linked on each minimum measure the Town of Hudson's that refers to this survey. website. Responses/results of the survey will be analyzed for reporting and evaluation. FINAL NCTo n of H d on April 17, 2021 Page 30 19. Stream Cleanup Provide votumcC'for ongoing citizen Participation through stream cleanup activities. If a safely accessible stream with litter/debris an excess of built up cannot be located, or built up litter will not take enough time to clean, stream side educational as an activities will be providedsupplement. These educational educational activities will focus on educating Participants on water quality and have the opportunity for hands on activities involving water bodies. 1. Hold stream cleanup efforts by engaging groups to conduct stream cleanup activities in appropriate areas. The events will b t promoted by he Town and WPCOC, with a focus on civic groups. 1. Permit Years 1-5 For the Town of Hudson the stream cleanups will focus on Gunpowder Creek and/or water bodies that feed into it to help uprove water quality and provide personal awareness for 2. Provide all matena for sffeam cleanup activities (i.e. gloves, trash bags, and trash pickers) hosted by 2. Permit Years I-5 1. Number of stream cleanup events held; Number of stream cleaTRIP participants; Number of flash bags filled. 2. Number of stream cleanup materials distributed. FINALNCTo tin of H dso Npril 19, 20 I Page S WPCOG will publicize permit Years 1-5 the event (hosted TCOG) to the public to gather volunteers for stream cleanup efforts to assist in public awareness and involvement. The event will be posted on the WPCOG website, The Town website, and flyers will be distributed at Town �---- 4. Annuauy 4 if streams do not have adequate litter Permit years 1-5 available for cleanp supplement or replace stream clean-up time with outdoor educational activities 3. Was the event publicized? Yes, No; Status; Number of part cipants per event. 4. Numner ui supplemental act vit es held; Number of participants n supplemental activities; FINALNCTo nofHudso April 19, 2021 Page 32 HAR GE DETECTION AND ELIMINATION PROG pART 7: ILLICIT DISCRAM e Detection and Elimination (IDDE The Town had not developed written procedures for MS4Inspect on Report for the Town °f Hudsono Illicit Discharge ..areas likely to have illicit Permit Citation II.D.2.a. IDDE Pr In response the Town will locate priori illicit discharges and trace sources, mplementing an IDDE Program. ram. discharges, conduct routine dry weather outfall inspections, identify of an illicit discharge, and evaluate and assess the IDDE program Illicit Discharge eliminate the source(s) action Report for the Town o Town has adopted and t Citation ILD2.b. Legal Anthont}' rovidethe The Town will also, in response to the MS4 sP regulatory mechanisms that p Detection and Elimination (IDDE)> Per m to the MS4. the MS4 will maintain a d ernf o bit ,licit sand discharges ance and ther re legal authority P of the map is in question and the Town The City of Lenoir provided a map of the Town of Hudson's outfalls and MSC locations dunng the accuracy In the future the Inspection; however the map was developed in ties ( c Storm Sewer System Refi to facilitate any MS4 act vit es (ILD.2. (permit Ref: 3.4.1 BMP 20) did not use the map late MS4 within Permit Years 3 thr°ugh 5 ( Procedures the comp or maintain written Town will be Mapping weather screening permit cy Weather Flow Program). Within the Stormwater In the last p cle, the Town d d not conduct dry quarterly, Data such as fox dry weather field activity ILD.2.d. Dry weather screening q GIS. Manag acted outfall, and photos of outfall will be recorded n ement Plan a schedule is to be created to conduct dry roach to Illicit date screening occurred, location of insp Pas has taken a reactive approach D,t e.P A list of violators were provided to DEQ The Town of Lenoir, on behalf of the Town of Hudson, in the P Discharge investigations with no wnttI procedures di ale, as stated of the cases did not have a documented resolution (II.D2.f•) t dating back to 2111; t Gy however a major ty proactive stance will DE Plan to establish written Procedures. A p s unclear if any Of the violations were e i the Town of Hudson. Within the new below, the Town will befaadopting application to track and document IDDE cases. This will allow the be initiated with the use °a areas basGIS ed on historical data. illicit discharge and illegal Town to identify priority al staff and the general public to identify 0 orn'..res. Previously, no Further, the Town will train Municipal es and dumping 2 & h.). Educational materiaam l will be available to help educate n through the use of educational outreac public abort hazards as with illicit discharges training had been administered (u-D' general p public empl°Pees, businesses, and the g e portal or by phone; the improper disposal of waste. through a webpag P hone number, h nts of any kind could be subm tted to the Towni The stormwater hotline Pill e Public comp unication was not publicized (Ii.D )' e areas of this plan, portal. A however the line of comet COG p as menrioned n the Public education and outreach and Illicit disc erg established on the WP an ems l tool on the WPCOG webpage. COG website. A link from the Town' website will lead to the citizen can make a complaint via hotline number or through rt and ean Disch manage, implement, document, repofollowing illicit discharge age ram which shall, at a minimum, include the The Town of Hudson will develop, Detection and Elimination prog detection and elimination BMPs. FINALNCS000605 SWMP Town of Hudson April 19, 2021 Page 33 20. Map 1. Update existing maP I Develod mainta n a to nclude open municipal storm sewer system channels and storm stormwater map including drain information and conveyances, flow direction, flow, direction. This major outfalls, and the waters of data will be collected the United States receiving through a mixture of stormwater discharges. The map laced onto an arc -online preexist ng map data will be p following its map to make it multi -use and validat on), as well as easily accessible for stortnwater field work based off or IDDE issues. public Works and the Planning Departments Recommendation and known information. f MS4 mapping will be completed each year (miles of pipe type of pipe, number of SCMs, number of outfalls, flow direction located, number of conveyances mapped re receiving bodies located/marked). Maintain Legal Authority 21. — 1. PennitYears 1-5 2. Add new infrastructure to map as new construction occurs, updated on an 2. Permit Yeazs 1-5 1, Was the map updated Yes, No; Status. Was at ]east 20% of the MS4 area mapped? 2, Was new infrastructure added to the map: Yes, No; Status gl]L'ALNCS000605 SWMP Town of Hudson April 19, 2021 page 34 (Section 7 of Town of Hudson Phase 11 stOrmwater ordinance) in order to maintain the legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping SPintills o the MS4, including forcementprocedures and actions. Update ordinance if required. ordinance and update f revision is required. Permit Years 1-5 Revisions will require council re -approval. 22. IDDE Plan Establish a written IDDE Plan to detect and address illkcitand discharges, illegal dumping any non-stormwater discharges identified as significant contributors of pollutants to the MS4. 1. Develop IDDE Plan to define the procedures of dentifying, tracking and processing illicit discharges, illegal dumping and sI gnificant contributors of pollutants to the MS4. Submit IDDE Plan to DEQ for approval. the ordinance needed? Yes, No; Status, developed? Yes, No; status; Date draft planis submitted to DEQ for approval. F31bALNCTn dnofH dMP April 19, 2021 Page 35 processes defined n the IDDE Plan and what is required by the IDDE ordinance. See BMP 27 3. Implement/Enforce 3. See BMP 27 3. the IDDE Plan and IDDE Ordinance. 23, Location of Priority Areas 1. Were priorityareas L Annually, located? Yes, No; Establish and maintain procedures I. Use MS4 map likely to locate outfalls near Status, areas l ke for locating priority high pollution risk Permit Years 1-5 have illicit discharges. A high Number of Priority areas. As BMP 20 is priority area is an area that has a being completed, areas added upon high chance of stormwater priority areas will be revision. pollution potential: Areas with established. The known dry weather outfall priority areas will be flows/violations, repeat offenders, e-evaluated on an business/commercial areas, annual basis to add industrial areas, and businesses additional high priority with high pollution potential. areas should they be found or new ones develop. Dry Weather Ootfall Inspections Permit Year 11. Were procedures 24' 1. Establish a . 1 weather (no and the schedule Perform regular dry outfall procedure to divide the established Yes, No; rain inpreviousprevious hours) Town and create a Status. inspections to proo actively identify hedule for dry illicit discharges and illicit scections for connections. The Town will be weather insp broken into 5 sections, with at known outfalls. 2 Annu�ly 2. Number of dry least one section e(20 )being 2, Implement dry weather inspections inspected each p year, The weather inspection completed; inspections will consist of the rocedures. permit Years 2-5 currently known outfalls and P Number of potential expanded with the progress of Date inspections illicit discharges (from BMP 20. occurred, location of dry weather flow) inspected outfall, and identified. photos of outfall will be documented- FIT,,'-kLNCs000605 nofHudson April 19, 2021 Page 36 25 Illicit Discharges and Trace Sources __ Establish procedures to track and 1. Establish procedures 1. See BMP 27 to track verified documentI1liritDischarge discharges and trace investigations. sources. intain and Implement IUUr - Maintain and hoPlement the IDDE Plan to detect and address illicit dischatges, illegal dumping and any non-stormwater I discharges identified as significant contributors of pollutants to the MS4. Ma 26. 2. See BMP 27 cr -� areas 1. Armuauy> 1. Seen p likely to have illicit scharges � BMP 23)• Permit Years 1-5 di 2. Investigate and 2. See BMP 27 Enforce IDDE issues. 3. Evaluate and assess 3. Annually Che IDDE Permit years 1-5 plan/program — Identify where improvements can be made based on data collected. Changes must be approved by DEQ from the previously approved IDDE Plan. See BMP 27 2. See BMP 27 1. Number of illicit discharges found in priority areas. 2. See BMP 27 3, Were revisions to the IDDE PI an needed? Yes, No; Status. FINALNCS000605 SWMP Town of Hudson April 19' 2021 Page 37 DDE Tracking 1 permit year 1 1. was the IDDE tracing sheet Staff will create a mechanisthmefor track ng sheet foDE developed? Yes, No; tracking and documenting illicit tracking IDDE Status date(s) an illicit dischazge, violations, recording connection or illegal dumping who made the Date IDDE sheet was was observed, the results of the complaint, location of developed. investigation, any follow-up of complaint note prior the investigation, the date the IDDE violations, investigation was closed, the status of the issuance of enforcementonictionsolators. investigation and and identifying actions taken. 2. Number of verifie 2. Record illicit 2. Continuously, IDDE issues- discharge/connection permit years 1-5 and illegal dumping reports/investigations on the IDDE tracking sheet. Differentiate staff discovery from citizen rePorting to allow for review of outreach program. 3. Upon mvesuga.,...-, enforce Illicit Discharge/connect on and Illegal Dumping violations to ensure the responsible party/violator remedies verified illicit 3. permit Years 1-5 3. Number of violations/enforcement actions issued; Number of violationslenforcement act inns resolved. FINAL NCTo n of Hudson April 19, 2021 Page 38 maintain a list of permit Years 1-5 chronic violators, as applicable. Updated on 5. Evaluate and assess the IDDE tracking sheet — Identify here mprovement can be made based on data collected, problems encountered and needs. Evaluation of the sheet will be done on an annual basis to find shortcomings with the IDDE program should they be Zg, Staff Training Train municipal staff and report contractors to denlifyt p illicit discharges, connections, illegal dumping and spills. a permit Years 2-5 1. Idenhry sraii members and/or contractors that are likely to observe an llicit discharge, illicit connection and illegal violators identified. 5. W ere revisions to the IDDE tracking sheet needed? Yes, No; status 1. See BMP 11 1. See BMP 11 F'INALNCTo�ofH dson April 19, 2021 Page 39 events to educate staff and contractors in identifying and reporting illicit discharges, illicit connections, illegal dumping, and spills. Tra Wings will have a sign n sheet to track the names of trained individuals. 29, IDDE Educator 1. See BMP 12 1. See BMp 12 ro re staff 1. Train hotline Establish apPiat p contacts in IDDE contacts for field inquiriesawareness, complaint regarding IDDE education, call protocols, and outreach and complaints. During IDDE enforcement, an outreach appropriate contacts for referral. 2. See BMP 12 approach to 'raise awaroblematic 2. Utiliz ng social why the violation s P d e °2. See BMP 12 i will be taken (See BMP 12). The media anthae hotline will also function as a WPCOG webp g to IDDE publicize contact mechanic forresponding the public. b i information for IDDE questions from the p reporting es, illegal dumping and spills. The mechanism al 34416 ID AE Reporting b appropriately trained Permit public and staff to report illicit dis ed o provide rapid responsey Ref. Measures fox the p and ball be managed D public? to facilitate reporting C ersonnel- B Annual R@Po A Schedule for Metric Hip Measurable Goal(') ! Ixn lamentation No%. Description of BIVLP 30, IDDE Reporting Hotline p, See BMP 12 1. See BMP 12 provide a hotline for the public 1. Utilize the hotline and municipal staff to report illicit (B IDDE repW 12) to receive reports. FI',NttLNCS000605 SWMP Town of Hudson April 19,2021 page 40 es, illegal dumping and 2. Train hotline staf to discharg differentiate between Spills. illicit discharge complaints and stormwaterlpost- construction complaints. The staff Will also be trained to keep adequate recor ds of the calls for metrics. 3. See BMP 12 3.P ublicize Hotline by 3. See BMP 12 including the phone number on educational materials. Post the hotline number on the Town and wPCOG websites and shared via social media accounts. 31. IDDE Reporting W eb-based Reporting Form ee BMP 15 1. See BMP 15 1. S Staff will establish and maintain a sewebfobm for ased web -based form reportingwhere IDDE complaints/reports can be entered IDDE reporting. and sent to the appropriate reporting individual. Publicize the reporting tool in education outreach materials as well as on the Town of Hudson webshe. 32 IDDE Reporting Efficiency 1. See BMP 1, See BMP 27 Staff will provide a sapid response A. Use the hIDDE eetonce to all complaints received. Staff tracking will record the response dates and to tralck time oished f 27) summary of results to improve IDDE program and tracking sheet complaint, site i to nt and type of comp all enforcement/resolution FINAL NCTo 0n of Hudson April N, 2021 Page 41 2. Evaluate response �>Lu t me. Work to m nze response Permit Years 1-5 imi t me to reported issues and record what is causing those issues to be fixed in later terations of the plan. ITrack the times elapsed between when an IDDE incident is reported, and when it 2. Average response time. FINALNCS000605 SWMP Town of Hudson April 19, 2021 Page 42 PART g: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM the Town of Hudson relies upon the NmthCarolina omeet a Of 1973 as a qualify ing alternative prog In accordance with 15A NCAC 0Ac .0153, Sedimentation Pollution Control Act (SPCA) e Pollutants n stormwater runoff from construction cons�ction activity that portion of the NPDES Mties that S4 Permit requirements for construction site runoff control measure . SPCA requirements include reducing p to one acre, and includes any result in land disturbance of greater than or equalox implemented by NCDEQ in non - Program common plan of development that would disturb one acre or more. The state SPC is part of a largerMown, delegated to a county, Program is either delegated to a city delegated areas. Alternative Program Components for Construction Site Runoff Control Program Table 16: Qualifying _� i _ . __m a, a P.ntity ar Par �p� m ted SPCA 3.5.4 uirements. The Town of Hudson also implements the following BMPs to meet NPDES MS4 Permit req 33. Municipal Staff Training Fdocumemation nicipal staff who receive m the public on the s for referral and of construction ff control comp L Train municipal 1. See BMP 50 staff on proper handling of construction site runoff control com la" s. 2 Continuously, 2. Ma nta n a list of tca ned municipal staff Permit Years 1-5 who have reported construction run-off ssues. 1. See 2. Number of construction run-off sues reported by municipal staff. Date trained staff reporting list was FINAL NCS000605 SWIvIP Town of Hudson April 19, 2 Page 43 Vleaos r�r•e�'thehotl ne, and Utilize the survey, the online form to give citizens metbods of responding to how construction runoff is being managed. The surveyhw" ask they questions regarding: unoff in the view construcho th think hould be Town, what. they hi upon u d caged to imp believe problems, and where they there should be more focus within the program. 35. W ante Manage= L. Use survey l�j° 1 g) to obtain feedback about public perspective about construction runoff in 2. Administer the survey. The survey will be linked to on the WPCOG stormwater webpage and the Town of Hudson website. 3. Utilize report ng form (BMP 15) that will allow citizens and the development community (separately distinguished) to write concerns and report construction runoff to report concerns about construction runoff issues via the online form on the Town and WPCOG websites and social 2. See BMP 1 2. See VIP 18 3. See 1. Develop an ordinance that addresses construction siLe waste. 15 1 4. See 15 fl t Y ear 1 1. Ordinance 1 Pernv developed: Yes or No, Status. F3NAL1�CS000605 SW1vIP Town of Hudson April M9 U21 page 44 2.Orinance aooprGu= Construction Site Runoff Control Bws developed 2. Permit earl d Yes, Status. 2. Adopt Require construction site he ordinance through operators to control waste cause council approval. BN1P 50 3. Se construction Site t that T quahty' 3. SeeBMP 50 e adverse imp 3. Train mun cipal staff on identifying and reporting construction waste 4 were any revisions violations. 4 Annually adopted to the waste 4. Maintain ordinance (if revisions permit years 2-5 management ordinance are needed). made? Yes, NO; Status. 5. Enfor d niroe ante 5. using the tracking sheet to track and document construction site waste concerns and FFN.aCNCS000605 SW�'lp Town of Hudson April 19, 2021 Page 45 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM MS4 Inspection Rep al Authority, "At the time of inspection, the Town Report for the Town of Hudson —Post-construction Site Runoff Control Program ls lement the post -construction site runoff controls plans, Implementation Statue, Perm t C ord n�jGe to imp Legal rather than the Town of Hudson was utilizing a Caldwell County to conduct inspections ofpost-construct on cto ontrols." The program. The ordinance authorized Caldwell County, rather request information, and enter private Property adopted a sto mwater Ordinance, hich authorizes herant ng the Town of Hudson has developed and than the County protective covenants (II.F.2.e J is be included. to administer the aforementioned items. W ithm the ordinancelanguage Town of Hudson the ability to require deed restrictions and p and within the �6.B.1, 2, Along with the WPCOG, n inventory of projects will be established (BMP a private Contracting Staff theser-annually and certified by p municipal limits, this is n response to Permit Citation II.by St of the latest audit (20ce . list proactive inspections will be adm ministered Upon non-compliance, enforce memnet mecacthanism will inventory P to ensure SCM functionality engineer annually Practice in years past, but now the Town will have a GIS track ng be taken, not a common P compliance as 2.i.). proactively enforce to obtain comp of Lenoir, on behalf MS4 Inspect on Report for the Town of Hudson — le Post -construct Site Runoff Control Program SCMs t in the permitted area specifically to ty sth' Implementation Status, Per ntt Citat on: ILF.. Nutrients tees withn the MS 1 3.care receiving discharge of the Town of Hudson had not designed or constructed any reduce nutrient loads. At this time it is uncleaz if the co-p into the nutrient sensitive waters. m lement and enforce a program to address than or to This SWMP ment and redevelopment projects that disturb greater tdentifies the minimum elements to develop, P er common Plan of developmentrn or stormwater runoff fio o ects less than one acre that are part of a laxg one acre, includ ng P 7 u are uali impacts utilizing a combination of structuraapd ensure adeqate long- ntrol sale, that are located with n the Town of Hudson and discharge nto the MS4. These elemen s designed to minimiazne�o tnon-structural BMPs appropriate for the commumty> Ivleaswes (SCMs) term operation and maintenance of SCMs. lements the following the Town of Hudson imp ost-construction the NPDES Phase II MS4 p where In accordance with 15ANocA�0 eq oementsawhich satisfy pps) in the MS4 area(s) State post-constructio rogr is are implemented, as Qualifying Alternative Programs) (Q site control they are FINALNCS000605 SWMP Town of Hudson April 19,2021 Page 46 Town of Hudson Watersheds �— Watar SupPtY Watershetls. �. Legend Hudson Townlmits P te�teE AreaWSIV „G Wj r Roatla e n Hudann ETJ :.Road$ 3 -'ll i mLimt Stearns !,Rivers N^ LenoirGKY Lnrl s A O I hs Mounteln Town Lirrais O Is 0 The Town of Hudson has existing requurements including the presents of a Qualifying Alternative Pxogram(s) n a portion of the Town limits. The Qualified Alternative Program is the Lake Hickory water supply watershed Protected Area WS-IV. To ensure complianceeth thecNP act on standards post- constructionprogram requirements the Town of Hudson appcat p throughout the Town Limits, including the area that is located �lementat on pehBMP 38 B 3-4, and are are to be adopted as local ordinance(s) per BMP 38.B.1 •and imp summarized in Table 19 below. FINALNC40000605 SWMP Town of Hudson April 19, 2021 Page 47 _ n.nRram Elements ....� e r the Host constructionprogram are Provided in table ��• """ gfNALNCS000605 SWMP Town of Hudson April 19, 2021 Page 48 Post Construction Site Runoff Control BMPs 1. Continuously 1. Track number of Permit hears 1-5 [mplement standardized tracking, low density and high documentation, inspections a t pile density plan reviews reporting mechanisms to comp erformed. appropriate data for the annual P self -assessment process. Data 21 Cont nuously shall be provided for each Post- 2. Track nu aner d high Permit Years 1-5 ua" m low density Construction Q �' g density plans Alternative Program being ov plemented as listed n Tables 3pN aintain a current 3. Continuously 18 and 19. inventory of low Perm t Years 1-5 density projects. and constructed SCs including SCM type or low density acreage, location and last inspection date. 4. Track number of SCM inspections performed. 5. Track number of low density inspections performed. 6. Track number and type of enforcement act ons taken. 37. Qualifying Alternative Program uirements are applicable to a portion The QAP re 9_ nr.9inance is being adm 4. Continuous') permit Years 1-5 5. Conttnuuun�y pest years 1-5 permit Years 1-5 reviews perlormed for ]ow density and high density. 2. Numoer m y.u.. approvals issued for low density and high 3. SummarY of number and type of SCMs added to the inventory; and number and acreage of low density projects constructed. 4. Numoer c inspections. 5. Number of low density projects nspected 6. Number and type o enforcement act ons issued fiilfill bothorequu ments e Phase II Post- EINAC:NCT won ofHud on April 19, 2021 page 49 38 phase H Post -construction Stormwater Ordinance ted and will J. Tra n staff (field The Town has adop and office) in maintain in effect the Phase II Stormwater Ordinance Stormwater Ordinance, which procedures and gives the Town legal author ty to nforcement actions. review designs for new development and redevelopment, 2. Enforcement of e Phase II Post - to ensure adequate Stormwater construction controls, to request information, to perform inspections on private Stormwater Ordinance to ensure compliance. property, and to perform other Should the correct compliance activities related to processes and order this measure. not be followed, a The ordinance references the DEQ BMP Design Manual as the betissued to address ce of violation ill source of standards to be used m the violation. selecting, designing, evaluating, and maintaining structural and 1. See tsrvxr '� 2. Continuously, permit Years 1-5 1. See BMP 50 2. Num— b 4ces of violationsissued; Number of Civil Citations issued; Number of still in progress of abatement at time of annual report. FIN AL NCTo n of H d on April17,2021 Page 50 Plan Review and AppCova 39, Review plans for all new development and redevelopment sites that will disturb greater than or equal to one acre (including I projects less than one oacre ltan of e part of a larger comet P development or sale). 1. Review p and submittal to Permit Years 1-5 documents annually determine if items need to be added or Pa All required submittals (as defined by the plan review procedures) must be received by the reviewer before the issuance Of a Certificate of Occupancy (per development). Should the procedures not be followed, a notice of violation and stop work ordered in h thell be Town'suordinance and ce SOP. modified. 2, See BMP 36 2. Review plans for all new development and redevelopment sites that will disturb greater than or equal to one acre. This is including less than one acre that are part of a larger common plan of development or sale. This requirement also applies to Federal, State and Local Government The Town of Hudson requests that the County holds the Certificate of occupancy on all developments that fall under stormwater regulations within the Town. The CO is issued until all stormwater requirements (designs, submittals, and inspections) are saUsf ed and the Stormwater Administrator approves the issuance. prolc���� 3, See 3. Maintain the sheettt g SCM Inventory Said sheet tracks all required submittals, relevant information, and all projects within theTown that have one through (and/or the are going through ) stormwater review procedure. 1. We Ur ce ce—anges to tha procedures/submittal documents needed? Yes, No; Status, 6Y� 3. FiN.�-NCS000605 SWMP Town of Hudson April 19, 2 page 51 40. Operation and Maintenance greet. Ensure that each 1. Continuous projects with O&M The Operation and Ma tire" cc project has an approved tans that received their (O&M) agreement requires O&M Agreement and Perm t Years 1-5 CO. owners of structural BMPs to O&M Plan prior to CO, perpetually maintain and operate to the O&M to be included in the BMPs according project checklist and plan submitted during the plan required prior to CO. review process and require Each O&M agreement submission of annual inspection ualified will include a a reports written by q requirement for annual professional. Each O&M inspections, agreement shall include an enforcement component defining the actions the eTown canfoDtake dif the O&M P 1. See BMP 36 41. Recordation ocess shall 1. Ensure each project 1. See BMP 36 The plan review pr has recorded deed include verification that permanent legal mechanisms are restrictions rotectivescovenants in in effect ensuring the project is P effect to ensure built consistently with its Tans. This will be development activities approved p h the submittal of will be maintained verified throng consistent with the an engineer's certification and roved plans (low providing an as -built. These must p density and high be received and accepted to ro ects . 2. See BMp 36 approve the issuance of that 2 Ensure that each 2. See BMP 36 projects CO. SCM and associated A recorded deed restriction or maintenance access areas are recorded in a protective covenant, along with an access easement is established permanent easement to through recordation. Recording both guarantee access for boththe access easement and inspection and b restricons' Certificate Of maintenance of the FINALNCTQ OnofH dson April 17, 202] Page 52 Table 20: Post Construction site Runoff Control BMPs Permit 3.6.4» Inspections ands nforcement inspection and enforcement authority, standards and procedures to: (a) Conduct post Ref. Measures to maintain insp or a Temporary Certificate of Occupancy. construction inspections prior to issuing Certificate a surety f Ord to guarantee compliance pliance with the approved plan(s), :Alternatively, the project owner may p c Ensure annual (b) Ensure that the project has been constricted n accordance with the approved plan(s), ( )ce inspection ofeach permitted SCM to ensure complianceroects at least oiiceodnring the permine n� nand (e) Regmte Agreemem (d) Ensure inspection of low density p 1 that inspections be conducted by a qualified professional. C D A B B1YSR schedule for Annual Reporting Measurable Goals) Metric No, Description of BMP Im lementation 42, Inspection and Enforcement 1. Number of pre -CO After project completion, but 1. Prior to issuance of a 1. COnt nuously inspections completed prior to issuance of a certificate of CO, a qualified Town occupancy, an inspection will be representative shall Permit Years 1-5 Number of repeat completed by a qualified perform an inspection inspections required. professional to ensure the project on all project SCMs to has been constructed according to ensure compliance. If the plan/design. Following corrections are approval, annual inspections by a required, then follow qualified professional will be up inspections will be completed. Low density projects performed until the will be inspected once in a permit SCM and project site is term to monitor potential compliant prior to the impermitted expansion and apply issuance of CO. enforcement if violations are 2. Number of SCM found. 2. Staff will perform 2. Annually, inspections of all SCMs inspections completed. (both government and Permit Year 1-5 Number of failed SCM non -government) ins ection within the Town. 3. Number of qualified 3. Owner shall have a 3. Annually licensed professional Qualified Licensed inspections completed Professional perform an Permit Year 1-5 with documentation SCM inspection in received. accordance with the O&M Agreement and Number of SCMs DEQ SCM manuals under annual inspection once a year. enforcement. FINALNCS000605 SWMP Town of Hudson April 19, 2021 Page 53 4. Annually 4. Number of low ost Construction Site Runoff o4�Co d snspectum density inspections of pYears 1-5 20/ of low -density Peru done; Number of low density violators found. projects each year (See Number of low density BM? 36 for inventory). enforcement actions Docnmen----- tat1OII—L,owDensity Ensure tr and records are maintained on low density projects to ensure t nop°ages inspection, imp can be determined, and corrective actions taken. $nsure informational materials are available on the WpCOG website to guarantee accessibility outside of office hours. Through traclang and inspections chronic violators will be identified. 20 oect dthe ow per density sites will be nsp P year. 1. Maintain low density project list to nclude existing sites. 2.Inspectthe completed low -density projects to ensure the projects have not expanded into a high density classification thus needing a SCM. Documentation — gigh Density 44. �-- 3. Pro tv d e ce ud ational material to the general public about low density developments: during the issuance of zoning permits, distributed through mailings, posted on social media, and handed out at events. See 2. See 3. 36 1. See BMP 36 42 42. See BMp 4'. PennitYears 1-5 3. Number of low density educational matey als distributed. FLN AL NCTo� of Hudson April 19, 2 page 54 Post Construction Site Runoff Col, Mai i an 1. See BMP 36 A. SeeBMP 36 Ensure tracking and records are inventory of all maintained on projects to ensure developments and that upon granting of final CO inspection redevelopments and follow-up ins p (public and private) with SCMs. Up impervious overages can be date determined and corrective actions inventory as projects taken. Ensure informational are reviewed, materials are available online tt ved, and guarantee accessibility of approconstructed. Continuously 2. Number of high office hours. Through track ng density informational and inspections chron c violators mprovide e° ado developers permit Years 1-5 materials distributed will be identified. about high density development. At a minimum, hyperlinks will be maintained on the Towns web page directed to the Ordinance and to the BMP Design Manual. Printed materials will be distributed (but not limited to): during the issuance of zoning permits, distributed through mail, digitally posted on social media, and handed out laced on the at events. 3. Items p 3. Establish links to all 3. Annually vvebpage: Yes or No, ordinances, manuals, Status Permit Years 1-5 policies, checklists, laced design standards, Were items rep and/or other materials with current versions if on the WPCOG revisions were website. required? Yes, No; F'INAI-NCTo nofH d on April I9, 2021 Page 55 45. Fecal COhfnrm Reduction 1 Annually Protective measures have been 1. Maintain Pet Waste e tot Years 1-5 established throughthe onent o adoption of reduce the amount of Permit the pet waste comp et waste. Phase 11 Stormwater Ordinance. p 2 Continuously, 2. Develop and The majority of the Town of supply septic tank Hudson's wastewater is manageds aterials awarenes Permit Years 1-5 however m via a sewer system — through tanks within to the County there are still septic the pipCOG septic the Town that could become hPollution. tank program. These An outreach approach source of fecal will be flyers will be used to rai taken to assist in reducing this Septank Pollution e awareness of pollutant and raise awareness. and septic 1. DidPet waste Ordinance require revisions? Yes, No; Status 2, Number oT septw tank flyers distributed. g'gN tL NCTo n of Hudson Npril M9 V21 Page 56 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING pgpggAMS good housekeeping strategy for the provides a comprehensive pollution prevention and prevention and good housekeeping rs This SWMP p ark and open lementation of sevenrequired programs, which bons such address the Town of Hudson municipal facilities and operations. Pollution p accomplished through the ImP ollutant runoff from municipal operations such as p ultimate goal of preventing or reducing p space maintenance, fleet and building maintenance, new construction and land disturbances, an stem maintenance. municipal storm sewer syoperations includes the following Programs: Pollution prevention and good housekeeping for municipal 1 Municipal Facilities Operation and Maintenance Program 2. Spill Response Program ;. MS4 Operation and Maintenance Program eration and Maintenance Program 4, Municipal SCM Op 5 Pesficide, Herbicide and Fertilizer Management Program 6 Veh cle and Equipment Cleaning Program 7. pavement Management Program good housekeeping report the pollution prevention and manage,ho leroc and rep In response to the inefficiencies The Town oe Hf da°n TabWillle below for each required program. P BMPs as sp ed an inventory olluted identified in the MS4 Inspection Report, Permtt Citations ILG.2.a., the Town had maintain ossible ollutexs will be established. of rmwataar>mo�ti A lb ttoha�e otPeterminped wlnch facilities were at risk to genera e p s An O & M p g1 o ram will be established. (BEQ ro the SWMP and in Permit YeeahOn oan O & M pto g ate (II.G2 b' asdequired per A ex the acceptance of ns ected annually' Furthermore, the in facilities and SC were not being P orated in the Incorp Municipal SCMs were not inventoried to date; but "it is believed that the Town of (II.G2.b. c. & g•) owned structural stormwater controls" and maintenance for facilities Hudson does not have municipally op O & M pTOan > staff will be trained to determine appropriateG.2.e n thus area. The Town of Hudaqnnnces (II did n)t perform street and SCMs. To date staff had po training catch basins and stormwater convey maintenance, including cleaning Lenoir lid not evaluate BMP s based II G.2,d states that "The City of on their pollutant removal" in public parking lot maintenance, Several of the BMPemo°al in address rhesethis reference to streets, roads, and and ma retaining procedures that focus on pollutant developing, adoptang, s 59-62 address thus prior lack of evaluation and issue by u rements for street/parking lot impervious areas. Permit Reference: 3.7.7, BMP' schedules and req 60.B.2 program implementation. BMP 59 focuses on setting and collecting litterldebris, with BMPthe oils, BMPs 60 and BMP 61 focuses on minim z ng 62 addresses procedures for clean ng sweeping. outreach program. BMP the developed standard spill procedures as working in part as a community utilizing fluids, and debris thatc and from Car accidents by necessary according FINALNCS000605 SWMP Town of Hudson April 19, 2021 page 57 ns ection, and maintenance of said system. BMP In the audit, II.G.2.e addresses the prior lack of maintenance of the Town's storm sewer system, Permit Reference, 3.7.3, BMP's 48,51 focus on the tra n ng, p 49 develops the required o&M plan which defines procedures/schedules, BMP io trains MP 52ners on oninspection the maintenance on the system with documentation. the correct procedure, BMP 51 focuses on inspection along with its documentation; and BMP 5 addresses the audit problem itself by performing Previously, the use of pesticides, herbicides, and fertilizers in municipal facilities was not well tracked or manag appropriate (minimal) usage. esl as stated in Il.G.2.h. Permit Reference, 3.7.5, BMP 55 focuses to ensure all staff using Pesticides, herbicides, and fe contractotilizers ocert ficat ou as wall and copiewins of ermits of both municipal BMP 56 focuses on track ng staff and contractors. E.G.2.1 addresses inconstant/lacking training for municipal employees in regards to good housekeeping ro rams required by the permit. and pollution practices. This is addressed in: 47.B.5, 48.B.4, SO.B.1 BMP, 54.B.55 SS.B.1, 57.B.2, 58.b. , and o and n pra .Each of these BMPs focusing on each of the 7 p g correct waste disposal and cleaning of municipal side t the problem, addressing training, protocol, II.G.2.J addresses a lack of measures regarding vehicles/equipment. BMP 57 focuses on the washing requirements, and options for municipal vehicle operators. BMP 58 focuses on the other side of the issue, ensuring that vehicle maintenance facilities are correctly d sposing of waste and that perm ttng is Cnllnwed to ensure MS4 compliance. F'INALNCSTOo00nofH don Apri119,2021 Page 58 in BMFS 1. See BMP 47 Pollution prevention and Good Housekeep all 1. See BMP 47 st be 1. Insp An cl & M Planemnen ed, and municipal facilities to developed, imp determ ne which maintained for each mumciPal facilities require an facility with the potential to O&M plan to be generate stormwater pollution. developed. All These plans will define the facilities will be expectations of the facility in nspected once per regards to stormwatex MS4 emut term. regulations. Each municipal P licable facilities facility in which this is applicable App will implement an O&M plan. will be inspected The implementation of a plan annually (See BMP all binding 47 2, permit Yeaz 1 2. Number of facility entails signing a legally 2. Develop an O & M O&M plans document that defines the parry plan for each developed. charged with ensuring that the s correctly maintained municipal facility with facility the potential to and documentation of the enerate storinwater maintenance is adequate. The gollution. Each plan documents will also define the P procedures in how the facility will will define required be maintained to reduce the risk procedures per ollution. The applicable facility to of stormwater P O&M plans inspect, maintain and facilities requiring evaluate the facilities will be inventoried through BMP 47. Should the facility maintain risk of stormwater ollution. 3. permit Years 2-5 3.O Numbers facility and/or store vehicles, washing Implement the O&M plans procedures will be defined in the written O & M Plan implemented. facilities O&M plan. (per applicable facility . 4. See BMP 47 4. Enforce and inspect 4. See BMP 47 the facilities to ensure compliance with the O & M Plans. Municipal Facilities the existing 1. Permit Year 1 1. Is the facility list verification complete: The municipal facilities operation lit1. f Verify Yes or No, Status. plan will ensure list of facilities is and maintenance p correct by using tax the facilities are being cords and field visits. Date of completion managed/maintained in a way that re does not negatively impact water quality. The facilities will be maintained in a scheduled and weltdefined manner by FINAL NCS000605 of H dson April 19, N0 Page 59 performing rollfine nspecnons. �� a facility is subject to SPCC requirements, then specific nspection procedures will be completed per the SPCC requirements. At the time developing this Sl h' . of Hudson does not own a facility that would fall under SPCC requirements. Should one be re- evaluated and SPCC criteria are met, it will be managed as such. 48. Spill Response Z. Use tax aara aiiu facility visits to determine if the facility has a Potential pollutant and/or spill risk (Make note of 3. Pertorm�a�.�«� nspectionsto ensure the Town is following good housekeeping measures. 2. Permit Year 1 3. Annually permit Years 1-5 4. Document and correct issues found during inspections. if a facility is subj ect to SPCC requirements, then ensure the correct documentation is in place for compliance with the regulation/requirement 5 t Tar]] llluu��iy� facility staff on proper stormwater awareness and good housekeeping methods. 4_ Annually Permit Years 1-5 1. Develop a written spill response procedure plan for each facility that requires one. 1. Permit p with potential ollutants/spill risk. Number of potential SPCC facilities. 3. Numoer ui �a��- inspected. Number of SPCC permitted facilities 4. Number of corrective actions taken (SPCC permitted facilities andnou- SPCC facilities). 5. See BMP 50 1 1, Were the procedures created for all facilities that require one Yes, No; Status summary' gT]yAL NCO won of Hudson Npri119,2021 Page 60 Spill %program for facilities and operations that store and/or use materials that pose a spill risk. The program will be designed in away that tracks potential polluting facilities as well as defining the procedures/materials required for spill response in those facilities. The definition of reportable spills will be written in"following eachfacility spill response plans §143-215.85, �usekeeping BMPS, 2, hvplement the spill 2. permit Year 1 response procedures an ( er facility). 3. Mainta n spill 3. Annually response procedures in permit Years 1-5 response to problems that may arise from implementation of spill �— staff 4. Train facility on spill response 5. Respond to spills as fey occur and manage the spills following established spill procedures. Reportable spills (per §143-215.85) will be reported to DEQ. BMP 50 4. See 5. PermitYeazs 1-5 response plans 3. Nurn of spill response procedure plans that required revisions. See BMP 50 5. Ntuvber of non - reportable spills. Number of spills reported to DEQ. FINALNCTo On of Hudson April i95202] page 61 49. MS4 Operation & Maintenance ( 1 Was the MS4 O&M 1. Develop an O&M 1 Permit Year 1 plan developed: Yes An O & M Plan must be plan to define the or No, Status. developed, implemented and P required procedures to maintained to follow the hedul requirements of the MS4 NPDBS s erformemaintenance Phase II Stormwater collection P system permit. Asa component of and evaluations of the improvement stor nwater collection this plan, a capital imp system The plan shall component will be included to cover inspection assist in prioritizing parts of the MS4 as determined by the MS4 schedules, standazd inspections (BMP 50) The O&M documentation, and staff res onsibilities. permit Year 7 2. W as the O & M plan must also be submitted to 2 2 Submit the plan approved by DEQ for approval. developed O&M Plan DEQ; Yes or No, to DEQ for approval. Status. Date of submittal to DEQ. 3 permit Years 2-5 3. Was the O&M Plan 3. Implement the implemented, Yes, written O M Plan, No; Status. 4. Cont nuously, 4. Number of MSl ted. 4. Administer the inspections comp O&M Plan (See BMP permit Year 2-5 51 & 52). PItY'ALNCTo nofH don April 17, 2�21 Page 62 51. Provideprovide tS¢ tS4 ra n ng to 1. Hold MS4 training events to educate staff municipal and contracted staff to on MS4 topics listed in minimize pollutants in the the referencing BMPs& stormwater collection system, Train all current prevent unnecessary damage and municipal staff on wear on the system, increase awareness of stormwater issues, Irermd essyeaofPri procedures on how regardless of prior Iand show the p to br ng them to deal with stormwater related trainingup to current issues. standards. This will cit reoccur at the beginning of each new permit cycle These tra n ngs will prevention, outreach, discharges> Pollution p outreach, how to respond to IDDE or post construction issues, spill prevention and response procedures, municipal facility requirements, construction runoff, Post construction ordinance and procedures, pesticide and fertilizer management, IDDE Plan procedures and requirements, IDDE ordinance, angod bousekeeping procedures, Inspection I . perm t Year 1 The topics covered and number of participants will be recorded at 2. Train any newly h red staff during permit years' 5 or were not previously trained on stormwater best management 2. Permit Years 2-5 1. Number of train ngs held; Number of personnel tra ned. 2. Number of trainings held; Number of personnel tra ned. F3N.AL NCTo qp of Hud on April 19, 2021 Page 63 inspections to ensure cSCMs and lines, non-functioning drainage inadequacies are dentified. 52. MS4 Maintenance nfrastructme (pipes, major outfalls, stormwater conveyances, and basins) to ensure functionality. MS4 inspections to ensure cjogged fines, non -function ng basins, and drainage inadequacies are repaired, if the municipality cannot reasonably maintain issues with MS4 infrastructure found in a permit yem, it can be contracted out to a qualified licensed professional if the Town chooses to do so. The town will utilize public works resources to ma nta n the Sol infrastructure; or the issue willbe included in the Towns capital improvement project list, and appropriately prioritized depending on the 1. 'on 1. Nuf catch mber o basins and conveyances Permit Years 1-5 inspected; Number of conveyance issues found reported. 1.Inspe 1' municipal catch basins and conveyances on an annual basis and/or upon report of maintenance being 2 M� �e will be completed upon fording through nspection or receiving reports of MS4 nfrastructure in poor condition. 2. Permit Years 1-5 1. See BMP 51 cleanings/maintenance actions performed. FINALNCTo dn6ofHudso April 17, 2021 Page 64 No. operation & Maintenance (O & M) 53, Municipal SCMs Op 1, See BMP 36 1. See BMP 36 The maintenance procedures and 1. Maintain an inventory of the Towns municipal inventorexisting o Tof owned SCMs will be kept up to date. SCMs with However, at the time of information developing this SWMP the Town including type= Yew built, date of last does not currently have a municipally owned SCM. Should inspection, and maintenance actions. the Town of Hudson need to 2. Cont nsly 2. Were any install one following expansion, 2 Develop and uoumunicipal SCM these procedures will be followed. maintain SCM O&M's developed? Operation and yes, No; Status, Maintenance Plans for each Town -owned SCM. 3. 3. See BMP 54 3. See BMP 54 Review/Update SCM inventory as necessitated by new Town develo went. 54, Municipal SCMs 1. Is the SCM list operation 1. Verify the existing 1. Permit Year1 complete: Yes or No; The municipal SC o a will list of municipal SCMs Status (Location and and maintenance program water structures itype to be ensure the storms correct by visiting determine documented). are being managed maintained in the typeland tes tcond condition. away that does not negatively Use mpact water quality. The SCMs Use aerial photography wiTown records to ll act maintained n a scheduled in conjunction with and well-defined manner written determine SCM in its O&M plan, location/ ownersh p. FINALNCS000605 SWMP Town of Hudson April L9,2027 Page 65 Table 21: Pollution Prevention and Good Housekeeping BMYs T aY the time of 2. Maintain Inventory this SWMP the Town of municipally owned does not currently have SCMs. Add all newally owned SCM. SCMs as they aree Town need to install constructed.ing expansion, theses will be followed. 3. Perform annual inspection and maintenance of municipally owned SCMs to ensure the operation and maintenance plan is being followed. 4. Document and correct issues found during inspections. 5. Should a municipal SCM be installed, Training on the maintenance of the SCM and its function shall be held. 55. Pesticide, Herbicide and Fertilizer Training to Staff 2. Continuously 2. Did the inventory require any municipal Permit Years 1-5 SCMs to be added Yes, No; Status. Total number of mun cipal SCMs 3. Annually 3. Number of municipal SCMs Permit Years 1-5 inspections done. 4. Annually 4. Number of issues identified/recorded; Permit Years 1-5 Number of corrective actions/repairs taken. 5. See BMP 50 � 5. See BMP 50 FIN.�lLNCS000605 SWMP Town of Hudson Apri] 19, 2021 Page 66 Measures to mrmmv�� •�-- quality impacts from the use of landscaping chemicals. The only staff wbo will be allowed to apply pesticides, herbicides, or fertilizers will be certified individuals who use methods that minimize the amounts used. -- staff on the use, storage, and handling to get officially certified. The training will include methods of using mine Ichemicals to reduce harmful effects, especially around SCM maintenance. Herb tic d aue d Fertilizer Ensure compliance with permits and certifications for the administering of pesticides, herbicides and r rtilizer to less�me application of product impactful to stormwater runoff. Only certified landscapers/ Isprayers are theories applying pesticides, herbicides, and 1. Maintaining copies of licenses/certifications of all staff and contractors who use landscaping chemicals. 57. Vehicle and Equipment Cleaning Prevent or rvnn" Contamination of Stormwater Runoff from all areas ent Cleaning' Vehicle and Equipment Wash water can be directed to the sanitary sewer or to vegetated areas. Where cleaning operations cannot be performed as described ahnve and when operations are P ennitYears l-5 1. Es andard Operating Procedure for containing and disposing of vehicle and equipment wash water. The procedures will be defined through the facilities 1. See 1. Number of certme municipal personnel. 1. FINAL NCTown of H d on April 19. 2021 Page 67 performed in the vicintty ox a storm drainage collection system, the drain is to be covered with a portable drain cover during cleaning activities. Any excess standing water shall be removed and properly handled prior to removing the drain cover. OR another acceptable method is installation of a SCM to capture and treat the wash water runoff. vehicle pollut on prevention trahling to 3. Wash all muntctpat light vehicles, Town emergency vehicles, and equipment using an established method listed under this BMP, or utilize a commercial carwash facility that contains and treats wash water where applicable. 4. Record washing procedures. Upon facility inspection (BMP 47) verify that documentation is being kept ensuring compliance and said documentation shows the facility is following the best management practices defined in their O&M 5g. Vehicle and Equipment Maintenance Measures to ensure that the waste generated by vehicle maintained at municipal facilities (included, but not limited to, oils, any running fluids, batteries, belts and other non -fluid vehicle waste) is being disposed of properly. 2. S7BIVP0ly Permit Years 1-5 1. Ensure the Town has obtained a NPDES industrial permit for all subj ect municipal facilities/operations 2. Perform waste inspections during facility inspections lSee BMP 47). 4. See BMP 47 1. Permit Years 1 2. See BMP 47 3. Number of vemcte washings performed; Was vehicle washing completed per this BMP? Yes, No; Status; Provide quarterly nvoices from commercial carwash if utilized. 4. See BMP 47 1. Log of industrial permits and status. Number of municipal industrial permitted 2. See BMP 4 FiNALNCS000605 SWMP Town of Hudson Apr l 19, 2021 Page 68 able 21:Pollution Prevention and Good Housekeeping BMPs 3. Provide routine 3. See BMP 50 3. See BMP 50 pollution prevention and waste management training to staff. Permit 3.7.7: Pavement Management Program Ref. Measures to reducepollutants'sn stormwater runoff from municipally -owned streets, roads, and parking lots within the permittee's; corporate limits. The permittee shall implement measures to control litter, leaves, debris particulate and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and documentation. A 13 C D BMP Schedule for Annual Reporting No. Description of BMP Measurable Godlls) Im lementation Metric 59, Street and Parking Lot Sweeping Measures to reduce pollutants in 1. Street/curb and 1. Annually 1. Total number of stormwater runoff from gutter sweeping will lane miles swept. municipally owned streets, roads, be done to reduce road Permit Years 1-5 and parking lots within the pollutants in runoff permittee's corporate limits. As with a focus on high the Town of Hudson does not priority areas prone to have a regular street cleaning buildup or higher service, streets will be chance of conveyance swept/cleaned annually. To damage/hindrance. supplement this, an outreach 2. Track 2. Continuously 2. Number of high approach and right of way conveyances/inlets that priority cleanings conveyances/inlets with frequent have frequent Permit years 1-5 done. issues will be prioritized. problems with pollution to prioritize their maintenance. FINALNCS000605 SWMP Town of Hudson April 19, 2021 Page 69 Table 21: Pollution Prevention and Good Housekeeping BMPs 3. Develop and 3. Continuously 3. Number of street distribute educational pollution flyers flyers regarding street Permit Years 1-5 distributed. runoff pollution to help supplement street cleanings. 60. Litter Management Collect litter in public areas and 1. Public waste 1. Continuously 1. Number of full time parking lots to reduce negative receptacles located on employees impacts on water quality. municipally owned Permit Years 1-5 responsible; parcels and within Number of trash bags Town right of ways are used. serviced on an as needed basis. 2. All other litter 2. Annually 2. Number of litter collection is performed pick up events on an as -needed basis Permit Years 1-5 utilizing available staff Weight of trash or community collected/disposed of volunteers. for each event (pounds); Number of staff and/or volunteers. 61. Leaf Collection Implement measures to control 1. Leaves are collected 1. Annually 1. Cubic yards leaves and debris within the with vacuum -style collected during municipal Town limits (to include equipment from Permit Years I-5 November to January. all properties). The Town of November I" through Hudson picks up leaves on an January 31 s'. Outside annual basis from November la` those months citizens through January 31 s`. can bag their leaves to be collected with trash pickup. 62. Vehicle Pollutant Management Measures to prevent and minimize 1. Train first 1. Annually 1. Number of first contamination of stormwater responders for responders (staff) runoff from vehicle pollutants minimizing, collecting Permit Years 1-5 trained and date of following an accident, and disposing of fluids paining. and other vehicular pollutants following an accident. FIN.4LNCS000605 SWMP Town of Hudson April 19, 2021 Page 70 Table 21; Pollution Prevention and Good Housekeeping BMPs 2. Continue equipping 2. Annually 2. Amount of materials the first responder used/replaced in kits. vehicles with spill kits Permit Years 1-5 and material containment tools. 3. Public Education to 3. Annually 3. Number of vehicle include infonnation pollution educational about vehicle leaks in distributed materials Permit Years 1-5 materials handed out, and other educational resources. 4. Illicit Discharge 4. Annually 4. Number of vehicle enforcement for IDDE issues significant vehicle Permit Years 1-5 documented; number leaks from parked cars. of vehicle IDDE issues enforced/corrected. FINALNCS000605 SWMP Town of Hudson Apri] 19, 2021 Page 71