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HomeMy WebLinkAboutNCS000444_Lowell Draft SWMP v2_20210113This page intentionally left blank Draft Stormwater Management Plan City of Lowell NCS000444 1/13/21 Lowell North Carolina Table of Contents PART1: INTRODUCTION ......................................................................................................................... 1 PART2: CERTIFICATION ......................................................................................................................... 2 PART 3: MS4 INFORMATION .................................................................................................................. 3 3.1 Permitted MS4 Area ...................................................................................................................... 3 3.2 Existing MS4 Mapping ................................................................................................................. 4 3.3 Receiving Waters .......................................................................................................................... 4 3.4 MS4 Interconnection ..................................................................................................................... 4 3.5 Total Maximum Daily Loads (TMDLs) ........................................................................................ 5 3.6 Endangered and Threatened Species and Critical Habitat .............................................................6 3.7 Industrial Facility Discharges ........................................................................................................ 6 3,8 Non-Stormwater Discharges ......................................................................................................... 6 3.9 Target Pollutants and Sources ....................................................................................................... 7 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ...................................10 4.1 Organizational Structure .............................................................................................................. 10 4.2 Program Funding and Budget ...................................................................................................... 12 4.3 Shared Responsibility .................................................................................................................. 13 4.4 Co-Permittees .............................................................................................................................. 14 4.5 Measurable Goals for Program Administration .......................................................................... 14 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM .........................................................16 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ...........................................21 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM ..............................24 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ...................................................28 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................30 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ......................35 List of Tables Table 1: Summary of MS4 Mapping Table 2: Summary of MS4 Receiving Waters Table 3: Summary of Approved TMDLs Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality 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-Pennittee 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 BMPs Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Table 17: Construction Site Runoff Control BMPs Table 18: Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program Table 19: Summary of Existing Post -Construction Program Elements Table 20: Post Construction Site Runoff Control BMPs Table 21: Pollution Prevention and Good Housekeeping BMPs PART 1: INTRODUCTION The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the City of Lowell will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent practicable. This SWMP identifies the specific elements and minimum measures that the City of Lowell will develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with the MS4 Perrot number NCS000444, as issued by NCDEQ. This pen -nit covers activities associated with the discharge of stormwater from the MS4 as owned and operated by the City of Lowell and located within the corporate limits of the City of Lowell. In preparing this SWMP, the City of Lowell has evaluated its MS4 and the permit requirements to develop a comprehensive 5-year SWMP that will meet the community's needs, address local water quality issues and provide the minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated annually to ensure that the elements and minimum measures it contains continue to adequately provide for permit compliance and the community's needs. Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along with any approved modifications of the SWMP, are incorporated by reference into the permit and become enforceable parts of the permit. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 1 PART 2: CERTIFICATION By my signature below I hereby certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. 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 ranking elected official. ❑X I am a principal executive officer for the permitted MS4. ❑ I am a duly authorized representative for the permitted MS4 and have attached the authorization made in writing by a principal executive officer or ranking elected official which specifies me as (check one): ❑ A specific individual having overall responsibility for stormwater matters. ❑ A specific position having overall responsibility for stormwater matters. Signature: J7Z Print Name: Scott Attawa Title: City Manager Signed this 13a' day of October 20 21 DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 2 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This SWMP applies throughout the corporate limits of the City of Lowell, including all regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits of the City of Lowell as of the date of this document. 5pancar Mnunlaln d V gr I% t u ''yr ay 4 f~ aL- R r 4e Cram Mrn z - City Limits Sou-ces Ean HER Ea :a. pan MEF1, Esr'� Cn.a1Hc np K---= - ETJ , *Note that ETJ is expected to be relinquished in Permit Year 1. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 3 3.2 Existing MS4 Mapping The current MS4 mapping currently includes the location of all existing SCMs and those that were under construction during our October 2019 audit. Future mapping efforts plan to include pipes, flow direction, inverts, open ditches, inlets, catch basins, manholes, outfalls, sizes, and conditions. (see 3.4.1) We anticipate this mapping to start in Permit Year 2 FY 22/23. https://www.lowellnc.com/DocumentCenter/View/780/M S4-Outfalls--SCMs-1 Table 1: Summary of MS4 Mapping Percent of MS4 Area Mapped 0 % No. of Major Outfalls* Mapped 5 total *An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch) directly into surface waters. Major outfalls are required to be mapped to meetpermit requirements. A major outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned areas a 12-inch diameter pipe or a drainage area > 2-acres. 3.3 Receiving Waters The MS4name MS4 is located within the Catawba River Basin and discharges directly into receiving waters as listed in Table 2 below. Applicable water quality standards listed below are compiled from the following NCDEQ sources: o Waterbody Classification Map o Impaired Waters and TMDL Map o Most recent NCDEQ Final 303(d) List Table 2: Summary of MS4 Receiving Waters Receiving Water Name Stream Water 303(d) Listed Parameter(s) Index / AU Quality of Interest Number Classification South Fork River 11-129-17 C 3.4 MS4 Interconnection The City of Lowell MS4 is interconnected with another regulated MS4 and directly discharges stormwater into the City of Gastonia MS4. The number of interconnections leaving the City of Lowell MS4 to the City of Gastonia is 3, as determined by both city's stormwater departments. Future mapping efforts will confirm this. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 4 3.5 Total Maximum Daily Loads (TMDLs) The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map and list provided on the NCDEO Modeling & Assessment [lint web page. The table also indicates whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program has been implemented to address the WLA. Table 3: Summary of Approved TMDLs Water Body Name TMDL Pollutant(s) of Concern Stormwater Water Waste Quality Load Recovery Allocation Program Y Lake Wylie TMDL Nitrogen, Phosphorus N N (WQMP BMPs are evaluated and designed to enhance water quality recovery. Public Education and Outreach: Public Involvement and Participation: IDDE: Pre and Post Construction Controls: Pollution Prevention and Good Housekeeping: The City of Lowell recognizes that the Lake Wylie TMDL 1995 Catawba River Basinwide Water Quality Management Plan points to a collaborative effort to deal with non point sources of pollution in to the South Fork River. The City of Lowell therefore has targeted certain industries and users with public education and involvement BMPs (BMP#8) to bring awareness and reform to improper practices such as the overuse of fertilizers and herbicides, improper waste disposal at automobile repair shops, and other household contributors such as home maintenance. As noted above, all BMPs are related to this reduction of pollution and enhancement of water quality recovery. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 5 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endangered species and/or critical habitat are not identified within the regulated MS4 urbanized area, as determined by a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Map and Listed species believe to or known _to occur in North Carolina map as provided by the U.S. Fish and Wildlife Service. Of those species listed, Table 4 summarizes the species that may be significantly impacted by the quality of surface waters within their habitat. Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality Scientific Name Common name Species Group Federal Listing Status Glyptemys Bog Turtle Vertebrate T (S/A) muhienber ii Myotis Northern Long-eared Vertebrate T se tentrionalis Bat Hexastylis naniflora Dwarf Flowered Invertebrate T Heartleaf Vascular Plant Helianthus Schweinitz's Invertebrate E schweinitzii sunflower Vascular Plant 3.7 Industrial Facility Discharges The City of Lowell MS4 jurisdictional area includes the following industrial facilities which hold NPDES Industrial Stormwater Pennits, as determined from the NCDEQ Active NPDES Stonnwater Permit List and/or Active Stonnwater Permits Map. Table 5. NPDES Stormwater Permitted Industrial Facilities Permit Number Facility Name None NA 3.8 Non-Stormwater Discharges The water quality impacts of non-stormwater discharges have been evaluated by the City of Lowell as summarized in Table 6 below. The unpermitted non-stonnwater flows listed as incidental do not significantly impact water quality. The City of Lowell has evaluated residential and charity car washing and street washing for possible significant water quality impacts. Street washing discharges are addressed under the Pavement Management Program in Part 10 of this SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the City of Lowell. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 6 Wash water associated with car washing that does not contain detergents or does not discharge directly into the MS4 is considered incidental. However, these types of non-stormwater discharges that do contain detergents have been evaluated by the City of Lowell to determine whether they may significantly impact water quality. The City of Lowell has evaluated the locations of where public works vehicles are cleaned as well as where the Lowell Volunteer Fire Department washes their vehicles and with the assistance of NCDEQ staff have determined that the locations are sufficient for protecting water quality purposes. Residential and charity car washes offer possible water quality impacts and the IDDE in Part 7 of this SWMP describes a methodology to investigate further. Public Education and Outreach in Part 5 of this SWMP identifies the ways in which the City of Lowell plans to educate target audiences about stormwater conscious car washing. Table 6: Non-Stormwater Discharges Non-Stormwater Discharge Water Quality Impacts Water line and fire hydrant flushing Incidental Landscape irrigation Incidental Diverted stream flows Incidental Rising groundwater Incidental Uncontaminated groundwater infiltration Incidental Uncontaminated pumped goundwater Incidental Uncontaminated potable water sources Incidental Foundation drains Incidental Air conditioning condensate Incidental Irrigation waters Incidental 5 Hn s Incidental Water from crawls ace pumps Incidental Footing drains Incidental Lawn watering Incidental Residential and charity car washing Possible Flows from riparian habitats and wetlands Incidental Dechlorinated swjnanaing pool discharges Incidental Street wash water Possible Flows from firefighting activities Incidental 39 Target Pollutants and Sources In addition to those target pollutants identified above, the City of Lowell is not aware of other significant water quality issues within the permitted MS4 area. Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the likely activities/sources/targeted audiences attributed to each pollutant, and identifies the associated SWMP program(s) that address each. In addition, the City of Lowell has evaluated schools, homeowners and businesses as target audiences that are likely to have significant stormwater impacts. Schools were DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 7 selected as a target audience due to the opportunity to affect positive change through education and involvement opportunities. Homeowners and businesses were identified as target audiences because they are likely sources of non -point pollution through uninformed management practices. Schools: With the onset of COVID-19 and the increased cleaning of many businesses and schools, the City of Lowell is becoming aware of increased levels of chemicals associated with cleaning products at our WWTP. Whereas these increased levels have been identified and accounted for with the treatment of the wastewater, staff has begun to communicate to the schools concerning the potentiality of future impacts that this could bring to the City of Lowell as it relates to not just our WWTP, but also stormwater. The City of Lowell will utilize Part 5 of this SWMP as the avenue to address this concern by reaching out to school's staff to identify their practices and evaluate that to the IDDE of this SWMP. Homeowners: Homeowners will be targeted with BMP information as it relates to pool cleaning, landscape maintenance, paint practices, and vehicle maintenance. Part 5 of this SWMP describes BMP flyers that have been created regarding these topics so that we may educate citizens to make better decisions when conducting maintenance at their households. Businesses: The food industry and auto repair and maintenance businesses will be targeted with BMP information. This outreach is detailed in Part 5 of this SWMP and will include mailed flyers and follow up conversations with businesses regarding best management practices. The construction industry will also be targeted with BMP flyers during the pre -construction permitting (Part 8). Table 7: Summary of Target Pollutants and Sources Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing Target Pollutant s /Audience s Litter Residents, Businesses, Schools Public Education & Outreach, Public Involvement & Participation Oil and Automotive Fluids Residents and Businesses Public Education & Outreach Cleaning Chemicals Businesses and Schools Public Education & Outreach Paint/PropertyPaint/Property Maintenance Residents, Businesses, Schools Public Education & Outreach Fertilizers and Herbicides Residents, Businesses, Schools Public Education & Outreach, Public Involvement General non -point source Residents, Businesses, Schools, Public Education & Outreach pollution Municipal Staff Illegal dumping Residents, Businesses, Municipal Public Education & Outreach, Staff Pollution Prevention and Good Housekeeping Sedimentation Residents, Construction Public Education & Outreach, Construction Site Runoff Control DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 8 Illicit Discharge Residents, Businesses, Municipal Public Education & Outreach, Staff I Illicit Discharge and Detection DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 9 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure CITY OF LOWELL ORGANIZATION CHART Lowell North Carolina DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 10 The Stormwater Administrator manages the SWMP and coordinates with the Assistant Stormwater Administrator for investigation of complaints, ensures good housekeeping procedures are being followed, and controls compliance to the MS4 permit. The Assistant Stormwater Administrator/Public Works Director manages their public works staff to assist in implementing the SWMP and the IDDE ordinance. The Administrator and the assistant continuously provide training related to stormwater BMP's issues. The Customer Service Specialists receives calls and manages the website information. Additional duties of the CSS also are to keep records of any stormwater inquiry for the review of the Administrator and to pass out stormwater education material to all new water account holders in the City of Lowell. Per the City of Lowell and Gaston County interlocal agreements, the Gaston County Natural Resources Department manages post construction runoff control and construction site runoff control within the municipal limits of Lowell. Table 8: Summary of Responsible Parties SWMP Component Responsible Position ,Staff Name Department Stormwater Program Planning Director Alex Blackburn Planning Administration SWMP Management Planning Director Alex Blackburn Planning Public Education & Planning Director Alex Blackburn Planning Outreach Public Involvement & Planning Director Alex Blackburn Planning Participation Illicit Discharge Planning Director Alex Blackburn Planning Detection & Public Works Director Thomas Shrewsbury Public Works Elimination Construction Site Stormwater Joseph Alm Gaston County Natural Runoff Control Administrator Resources Post -Construction Stormwater Joseph Alm Gaston County Natural Stormwater Administrator Resources Management Pollution Planning Director Alex Blackburn Planning Department Prevention/Good Public Works Director Thomas Shrewsbury Public Works Housekeeping for Department Municipal Operations Municipal Facilities Planning Director Alex Blackburn Planning Operation & Public Works Maintenance Program DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 11 Spill Response Program Public Works Director Thomas Shrewsbury Public Works MS4 Operation & Planning Director Alex Blackburn Planning Maintenance Program Municipal SCM Planning Director Alex Blackburn Planning Operation & Stormwater Joseph Alm Gaston County Natural Maintenance Program Administrator Resources Pesticide, Herbicide & Public Works Director Thomas Shrewsbury Public Works Fertilizer Management Program Vehicle & Equipment Public Works Director Thomas Shrewsbury Public Works Cleaning Program Pavement Management Public Works Director Thomas Shrewsbury Public Works Program Total Maximum Daily NA Load (TMDL) Requirements 4.2 Program Funding and Budget In accordance with the issued permit, the City of Lowell shall maintain adequate funding and staffmg to implement and manage the provisions of the SWMP and comply with the requirements of the NPDES MS4 Permit. The budget includes the permit administering and compliance fee, which is billed by the Division annually. The total stormwater department budget is $109,047 for FY 20121. Staff is actively working to research and develop a recommended stormwater fee for the City Council to adopt in order to alleviate the general fund. This program is currently under -funded to conduct all the elements of the permit. Further fiscal analysis and investigation of the fee will be conducted as indicated in BMP No. 3 in order to fund the stormwater program by Permit Year 3. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 12 stormwater Acct Description Salaries $ Budget Explanations/Comments 54,917 Salaries & Wages FICA $ 4,201 Employer FICA (7.65% of wages Health Insurance $ 16,076 Health and dental insurance Retirement $ 5,574 10.15%of salaries is retirement. 401(1(� $ 2,746 5% of salaries is 4011K) expense Professional Services Postage $ 150 Travel & Training $ 1,000 Main. & Repairs $ 5,000 Checking Acct Expense Automotive Suplies (Fuel) Supplies $ 1,900 Spill Kits, Educational Materials, Mapping Cost Contracted Services Dues & Subsriptions $ 1,350 Permit fee and Regional SW Partnership Dues Insurance & Bonds Capital Outlay $ 16,133 Leaf Vacuum ($16,133) Prin. Maturities - Bonds Interest on Bonds Totals $109,047 4.3 Shared Responsibility The City of Lowell will share the responsibility to implement the following minimum control measures, which are at least as stringent as the corresponding NPDES MS4 Permit requirement. The City of Lowell remains responsible for compliance if the other entity fails to perform the permit obligation, and may be subject to enforcement action if neither the City of Lowell nor the other entity fully performs the permit obligation. Table 9 below summarizes who will be implementing the component, what the component program is called, the specific SWMP BMP or permit requirement that is being met by the shared responsibility, and whether or not a legal agreement to share responsibility is in place. Table 9: Shared Responsibilities SWMP BMP or Legal Permit Requirement Implementing Entity & Program Name Agreement Y Part H Section E Gaston County Sediment and Erosion Control Program Y Part 11 Section F Gaston County Post Construction Program Y Outreach to Targeted Regional Stormwater Partnership of the Carolinas (RSPQ N Audiences, Volunteer -See BMPs No. 4 and 15 Opportunities DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 13 4.4 Co-Permittees The are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000444 for the City of Lowell. Table 10 summarizes contact information for each co-permittee. Table 10: Co-Permittee Contact Information Co-Permittee MS4 Contact Person Phone & E-Mail Interlocal Name Agreement (Y/N) NA 4.5 Measurable Goals for Program Administration The City of Lowell will manage and report the following Best Management Practices (BMPs) for the administration of the Stormwater Management Program. Table 11: Program Administration BMPs Permit 2.1.2 and Part 4: Annual Self -Assessment Ref. Measures to evaluate the performance and effectiveness of the SWMP program components at least annually. Results shall be used by the permittec to modify the program components as necessary to accomplish the intent of the Stormwater Program. The self -assessment reporting eriod is the fiscal year Jul 1 — June 30 . BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 1. Annual Self -Assessment Perform an annual evaluation of 1. Prepare, certify and 1. Annually for Permit 1. Annual Self- SWMP implementation, suitability of submit the Annual Self Years 1 — 4 Assessment received by SWMP commitments and any Assessment to NCDEQ (FYI 4/20 — FY22/23) NCDEQ no later than proposed changes to the SWMP prior to August 31 each August 31 each year. utilizing the NCDEQ Annual Self- year. Assessment Template. Permit 1.6: Permit Renewal Application Ref. Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the NPDES MS4 permit. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 2. Permit Renewal Application DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 14 Table 11: Program Administration BMPs Audit stormwater program 1. Participate in an 1. TBD --Typically 1, NIA implementation for compliance with NPDES MS4 Permit Permit Year 4 the permit and approved SVIIW, and Compliance Audit, as utilize the results to prepare and scheduled and performed submit a permit renewal application by EPA or NCDE . package. 2. SeIf-audit and 2. Permit Year 5 2. Submit Self -Audit to document any DEMLR (required stormwater program component of permit components not audited renewal application by EPA or NCDEQ package). utilizing the DEQ Audit Template. 3. Certify and submit the 3. Permit Year 5 3. Permit renewal stormwater permit application package renewal application received by DEQ at least (NOI, Self -Audit, and 180 days prior to permit Draft SWMP for the next expiration. 5-year permit cycle). Table 11: Program Administration BMPs Permit 2.1.1: Adequate Funding and Staffing Ref. The permittee shall maintain adequate funding and staffing to implement and manage the provisions of the SWMP and meet all requirements of this permit BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 1. Adequate Funding Perform a fiscal analysis and explore 1.Complete a fiscal gap 1. Annually for Permit 1. Report monetary value options to obtain adequate program analysis Years 1 of gap funding to fully fund the stormwater (FYI 9/20 — FY22/23) program and meet all requirements of the permit. Select and implement a funding strategy for the Phase II Stormwater Program. 2.Determine available 2.Continous in Permit 2-Completed? - funding mechanisms and Year 1 yes/no/status evaluate options 3.Select a funding 3.Continuous in Permit 3.Report mechanism mechanism Years 1-2 selected _ Once 4.Implement funding 4.Continuous in Permit 4.Implemented?- mechanism Years 2-3 es/no/status DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 15 PART S: PUBLIC EDUCATION AND OUTREACH PROGRAM The City of Lowell will implement a Public Education and Outreach Program to distribute educational materials to the community or conduct equivalent outreach activities about the impacts of storm water discharges on water bodies and steps the public can take to reduce pollutants in storm water runoff. The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the City of Lowell is required to inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping and improper disposal of waste. Table 12: Summary of Target Pollutants & Audiences Target Pollutants Likely Source s /Tar et Audience(s) Litter Residents, Businesses, Schools Oil and Automotive Fluids Residents and Businesses Clcaning Chemicals Businesses and Schools Paint/Property Maintenance Residents, Businesses, Schools Fertilizers and Herbicides Residents, Businesses, Schools General non -point source pollution Residents, Businesses, Schools, Municipal Staff Illegal dumping Residents, Businesses, Municipal Staff Sedimentation Residents, Construction Illicit Discharge Residents, Businesses, Municipal Staff Three existing city events, the Lowell Freedom Festival, River Sweep and the Arbor Day Celebration, will used as a platform for stormwater outreach and education. The City of Lowell will also further develop their stormwater web page and use social media to reach different target ages of citizens. Additionally, the City of Lowell will partner with RSPC to more cost effectively implement education and outreach activities. The City of Lowell will manage, implement and report the following public education and outreach BMPs. Table 13: Public Education and Outreach BMPs Permit 3.2.2 and 3.2.4: Outreach to Targeted Audiences Ref. Measures to identify the specific elements and implementation of a Public Education and Outreach Program to share educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The permittee shall provide educational information to identified target audiences on pollutants/sources identified in table 12 above, and shall document the extent of exposure of each media, event or activity, including those elements implemented locally or throu h a cooperative agreement. BMP A B C D No. Description of BM]? Measurable GoaI(s) Schedule for Annual Reporting Implementation Metric 4. Goals and Objectives DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 16 Table 13: Public Education and Outreach BMPs 5. 6. Local Public Education and Outreach Program based on community wide issues. 1. Participate in outreach programs in local schools to bring awareness to specific Lowell issues regarding stormwater. 2. To reduce the over use of lawn chemicals that result in contamination of stormwater and other non -point pollutants. 3. Partner with RSPC and develop multiple handouts of BMPs that are specific to the needs of Lowell. Describe target pollutants and/or stressors The City of Lowell shall maintain a description of the target pollutants and/or stressors and likely sources. Describe target audiences The City of Lowell will maintain a description of the target audiences likely to have significant storm water impacts and why they were selected 1. Stormwater fliers that cover the four topics below will be inserted into utility bill statements and distributed to all residents and businesses receiving a utility bill. Four topics covered: general stormwater awareness, illicit discharges, illegal dumping, and proper waste disposal. 2. The City's Facebook account will be used to spotlight certain target pollutants that are common in Lowell. 1. Maintain a list of past violations and where likely relative violations may exist (i.e.mechanics) and target those citizens/businesses with specific educational materials. County Natural Resources for public schools. Permit Year 1 FY21 /22 Continuous 2. Permit Year 4 FY23/24 Annually 3. Permit Year 1 FY 21/22 Continuous 1. Include flyer with all four topics in Permit Year 2, FY 22/23 Mail all four topics in one billing cycle annually 2. Permit Years 1-5, Annually 1. Permit Year 1, FY 21 /22 Continuous Holbrook Middle School students that attended stormwater workshops with the Gaston County Natural Resource Environmental Educator. 2. Sample nearby outfalls and measure contaminants. Use the results to drive further goals and objective 3. Is handout developed? Yes/no/status 1. Document and report the topic and number of utility bill inserts distributed. 2. Document visits and reach through website and social media tracking. Document the tonics covered. 1. Document violations, measure for reduction in future violations 1 compliance. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 17 Table 13: Public Education and Outreach BMPs 2. Identify key 2. Permit Year 2, FY 2. Document violations neighborhoods that have 22/23 during Fall aeration, the most significant Annually overseed and fertilizer impact to major outfalls time and track number of to the South Fork River occurrences on an and target those citizens annual/seasonal basis. with fertilizer awareness program/mailers that reduces migration of fertilizers into the stormwater system. 7. Describe Residential and Ndustrial/Commercial issues The City of Lowell shall describe 1. Use the City's social 1. Permit Year 1, FY 1. Document amount of issues, such as pollutants, likely media account(s) to post 21/22 people reached and sources of those pollutants, impacts examples and Annually amount of engagements and physical attributes of stormwater information regarding on social media. runoff, in their education/outreach stormwater education program. relative to pollutants and impacts on runoff among residential and the business community. 8. Distribute public education materials to identified target audiences and user groups. For example, schools, homeowners, and/or businesses. The City of Lowell shall distribute 1. Provide food industry 1. Permit Year 1, FY 1. Document the amount stormwater educational material to BMP flyers to local 21/22 of flyers mailed and any appropriate target groups. Instead of restaurants and waste Annually feedback. developing its own materials, the collectors educating permittee may rely on Public them, Education and Outreach materials 2. Provide Commercial 2. Permit Year 3, FY 2. Document the amount supplied by the state, and/or other Property Management 23/24 of flyers mailed and any entities through a cooperative related BMP flyers to Annually feedback. agreement, as available, when local apartment implementing its own program. companies. 3. Provide Landscaping 3. Permit Year 1, FY 3. Document the amount Management Industry 21/22 of flyers mailed and any BMP flyers to citizens, Annually feedback. new construction contractors and businesses. 4. Provide painting 4. Permit Year 2, FY 4. Document the amount Industry BMP flyers to 22/23 of flyers mailedihanded new construction Annually out and any feedback. builders to keep on the 'obsite. 5. Provide painting 5. Permit Year 5, FY 5. Document the amount Industry BMP flyers to 25/26 of flyers mailed/handed new construction Annually out and any feedback. builders to keep on the obsite. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 18 Table 13: Public Education and Outreach BMPs 6. Provide vehicle 6. Permit Year 1, FY 6. Document the amount maintenance operations 21/22 of flyers mailed and any BMP flyers to residents Annually feedback. and auto repair businesses. 7. Provide pool cleaning 7. Permit Year 4, FY 7. Document the amount industry BMP flyers to 24/25 of flyers mailed/handed residents known to have Annually out and any feedback. pools or pool contractors applying for permits. 9. Implement a Public Education and Outreach Program. The City of Lowell's outreach 1. Provide handouts of 1. Annually, Permit 1. Document amount of program, including those elements worksheets, puzzles, Years 1-5 those interacted with, implemented locally or through a coloring pages, word cooperative agreement, shall include fmds, prize giveaways, a combination of approaches etc to citizens of all ages designed to reach the target at annual festival. audiences. For each media, event or 2. Utilize the Regional 2. Annually, Permit 2. Document the activity, including those elements Stormwater Partnership Years 1-5 audience reach and implemented locally or through a (RSPC) for cost sharing location of viewership. cooperative agreement the City of of tv/radio advertising Lowell shall estimate and the record 3. See BMP#5 (above) 3. Annually, Permit 3. Document the amount the extent exposure. for industry distributed Years 1-5 of flyers mailed/handed BMPs. out and any feedback. Permit 2.1.7, 3.2.3 and 3.6.5(c): Web Site Ref. Measures to provide a web site designed to convey the program's message(s) and provide online materials including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit and SWMP. The web page shall also provide developers with all relevant post -construction requirements, design standards, checklists and/or other materials. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 10. Informational Web Site The City of Lowell shall promote and 1. Establish the 1. Permit Year 1 1. Document the date of maintain, an internet web site Stormwater Webpage FY21/22 the creation of the designed to convey the program's Once webpage. message. Other information included: 2. Provide the 2. Permit Year 1 2. Document the date of the MS4 permit, SWMP, applicable ordinances, reporting mechanisms, stormwater ordinance FY21/22 the addition of these educational materials, opportunities and erosion control Once ordinances. for involvement, and stormwater ordinance on the number, web a e. 3. Provide links to EPA, 3. Permit Year 1 3. Document the date of NCDEQ, RSPC and FY21/22 the addition of these other relative websites Continuous ordinances. for more information. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 19 Table 13: Public Education and Outreach BMPs 4. Update the webpage 4. Permit Years 1-5 4. Document the date of by posting the MS4 FY21/22 the addition of these Annual Self -Assessment, Continuous ordinances. verifying all links and contact info are current/active. 5. Add industry BMP 5, Permit Year 1 5. Document and report flyers for target FY21/22 the date posted. audiences that address Continuous *a hit counter is being pollutants commonly researched for all. found in Lowell and the 8 ways you can help flyer Permit 3.2.5: Stormwater Hotline Ref. Measures for a stonnwater hotline/helpline for the purpose of public education and outreach. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for bn lementation Annual Reporting Metric 11. Maintain Hotline/Help line The City of Lowell shall promote and 1. The stormwater 1. Permit Year 1-5 FY 1. Document when and maintain a stormwater hotline/helpline is 21/22 where this information hotline/helpline for the purpose of provided in the city Continuous appears. 1s hotline public education and outreach. newsletter, stormwater maintained yes/no/status website, all stormwater after year 1 literature that is provided, and is posted at City Hall. 2. Establish appropriate 2. Permit Year 1 FY 2. Yes/No/Status staff contact(s) to field 21/22 inquiries regarding Continuous stormwater education, outreach and complaints (see also BMP# for 1DDE Reporting) 3. Train stormwater 3. Permit Year 1 FY 3. Document and report education and hotline 21/22 number of staff trained, contact(s) in general Continuous training date(s) and stormwater awareness, topics covered. complaint protocols and appropriate contacts for referral of typical stormwater issues. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 20 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that complies with applicable State, Tribal and local public notice requirements. The City of Lowell's Planning Board will begin to function as the City's stormwater advisory board (in Permit Year 1) with an additional provision of a stormwater liaison to highlight stormwater issues. The stormwater hotline and a stormwater reporting mechanism on the website will be used to collect public input. The City of Lowell Planning, Public Works, and Parks & Recreation departments will continue to provide volunteer opportunities to prevent litter from entering the stormwater system with the annual river sweep and other events. The City of Lowell will manage, implement and report the following public involvement and participation BMPs. Table 14: Public Involvement and Participation BMPs Permit 3.3.1: Public Input Ref. Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 12. Volunteer community involvement program The City of Lowell shall include and 1. Volunteer opportunity 1. Permit Year 2, FY 1. Document amount of promote volunteer opportunities for litter sweep to teach 22/23 volunteers signed up and designed to promote ongoing citizen awareness of stormwater Annually those that were citizens participation. pollution. of Lowell. Document feedback from citizens and what topics discussed. 2. Volunteer opportunity 2. Permit Year 1, FY 2. Document amount of with Annual River 21122 volunteers signed up and Sweep and neighborhood Annually those that were citizens awareness of lawn of Lowell. Document chemicals with local feedback from citizens landscape supplier. and topics discussed. 13. Mechanism for Public involvement The permittee shall provide and 1. City staff will begin to 1. Permit Years 1-5, 1. Document dates of promote a mechanism for public bring stormwater issues Annually meetings and stormwater involvement that provides for input before the planning topics that were on stormwater issues and the board to receive citizen discussed. stormwater program. input and factor stormwater into development decisions. 2. Utilize the stormwater 2. Permit Year 1-5, 2. Document the total website for submission Continuously number of submissions. forms for asking a stormwater question or report a concern. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 21 Table 14: Public Involvement and Participation BMPs 14. Hotline/Help Line The permittee shall promote and 1. See BMP No. 11 1. See BMP No. 11 1. See BMP No. 11 maintain a hotline/helpline for the Continuous purpose of public involvement and artici ation Permit 3.3.2: Volunteer Opportunities Ref. Measures to provide volunteer opportunities designed to promote ongoing citizen participation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 15. Volunteer Litter Sweep Provide opportunity for Iitter cleanup 1. Identify areas that 1. Permit Year l FY 1. Areas identified — at city parks and recreation locations could be cleaned up by 21/22 yes/no/status that have impacts on stormwater volunteers. Once 2. Coordinate clean-up of 2. Annually, beginning in 2. Report the number of (BMP No. 12) public areas Permit Year 2 FY 22/23 citizens that participated and the tonnage/weight of trash removed. 16. River Sweep Provide opportunity for litter cleanup 1. Opportunity for 1. Permit Year 1 FY 1. Report number of at major outfalls to remove litter from volunteer to clean up 21/22 Lowell citizens becoming passed into the South Fork areas next to the South Annually participating River. (BMP No. 12) Fork River. 17. Partnership with RSPC The RSPC educated and brings 1. Conduct a workshop 1. Permit Year I FY 1. Completed? awareness to the public, local for HOA's to better 21/22 Y/N/Partial businesses and education centers of understand their Once Report Number of our region about stormwater issues maintenance agreements attendees and their impacts on water quality they have on SCMs. 2. Host an annual Elected 2. Annually, currently 2. Completed? and our environment. Officials workshop to ongoing Y/N/Partial discuss stormwater issues with our regional elected officials. 3. Participate in the 3. Permit Year 2 FY 3. Completed? public event RiverFest 22/23 YIN/Partial (Catawba River Keeper) Once, Annually if What topics were in Belmont to discuss offered discussed? stormwater with our local citizens. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 22 DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 23 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The City of Lowell will develop, manage, implement, document, report and enforce an Illicit Discharge Detection and Elimination Program (IDDE) which shall, at a minimum, include the following illicit discharge detection and elimination BMPs. The existing IDDE Program that is loosely held together with internal policies will be formally put together and adopted by the City Council and reside within the City of Lowell Code of Ordinances. Table 15: Illicit Discharge Detection and Elimination BMPs Permit 3.4.1: MS4 Map Ref. Measures to develop, update and maintain a municipal storm sewer system map including stormwater conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting hn lementation Metric 18. Maintain a Storm Sewer System Map of Major Outfalls The MS4 map creation will begin 1. Consultant selected to 1. Begin in Permit Year 1. Consultant selected? with the review of proposals to perform initial map 1 FY 21/22 Y/N/Partial identify and select a consultant. The creation and mapping. scope will be to map outfalls, known Conclude initial mapping Initial mapping pipes, structures, and flow directions. in Permit Year 2 FY completed? 22/22 Y/N/Partial 2. Map creation with 2. Permit Year 3 FY 2. Report when map is receiving waters added. 23/24 Once created 3. Map creation with 3. Permit Year 3 FY 3. Report when map is flow directions. 23/24 Once created 4. Map creation with 4. Permit Year 3 FY 4. Report when map is SCMs and other 23/24 Continuous created structures added. 19. Continually update MS4 Map Add new construction infrastructure 1. Maintain the outfall 1. Annually, once BMP 1. Report whether or not to the map continuously map with all new No. 18 is completed new outfalls were infrastructure of identified. How many conveyances and outfalls were identified during added yearly to the map, the permit year and how many during permit term. Permit 3.4.2: Regulatory Mechanism Ref• Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4, includin enforcement procedures and actions. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 20, Maintain adequate legal authorities DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 24 Table 15: Illicit Discharge Detection and Elimination BMWs The City of Lowell shall maintain an 1. Review City Code of 1. Permit Year 1 FY 1. Adopt the ordinance IDDE ordinance or other regulatory Ordinances to add an 21/22 by City Council. mechanisms that provides the legal IDDE ordinance and Once Y/N/Partial authority to prohibit illicit update to maintain legal connections and discharges within the authority. Lowell Code of Ordinances, perhaps Article V, that Permit 3.4.3: IDDE Plan Ref. Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4. The plan shall provide standard procedures and documentation to: a) Locate priority areas likely to have illicit discharges, b) Conduct routine dry weather outfall inspections, c) Identify illicit discharges and trace sources, d) Eliminate the source(s) of an illicit discharge, and e) Evaluate and assess the IDDE Program. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 21. Investigate sources of identified illicit discharges The City of Lowell shall maintain 1.Develop a written 1. Permit Year 1 1. Report Yes/No?Status written procedures for conducting IDDE Plan. Once investigations of identified illicit 2. Submit plan to DEQ 2. Permit Year 1 2. Report Date Submitted discharges. for review and approval, Once 3. Implement the 3. Permit Years 2-5 3. Completed? approved plan Continuously Yes/No/Status 4. Develop a SOP for 4. Permit Year 2-5 4. Completed? 3.4.3 a-e Continuously Y/N/Status 22. Enforcement of the IDDE ordinance 1. Train staff to 1. AnnuaIly after BMP 1. Report number trained implement the IDDE No. 20 completed. ordinance. 23. Conduct IDDE Inspections Conduct IDDE inspections in 1. Conduct inspections 1. Permit Years 2-5 1. Report number of accordance with the approved IDDE Continuously inspections report Plan number of confirmed illicit discharges, number of illicit discharges remedied, and number of illicit discharge enforcement actions. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 25 Table 15: Illicit Discharge Detection and Elimination BMPs 2. Staff should routinely 2. See BMP No, 23.1 2. See BMP No. 23.1 perform inspections of Annual inspections of the different quadrants of all quadrants. the MS4 Outfall Map by performing regular dry weather (no rain in previous 72 hours) outfall inspections to proactively identify illicit discharges and illicit connections. 3. 3. 3. 24. Maintain an Illicit Discharge Detection and Elimination Program Maintain a written Illicit Discharge 1. See BMP No. 20 1, Permit Year 1 FY 1. See BMP No. 20 Detection and Elimination Program, 21/22 including provisions for program Continuous assessment and evaluation and integrating ro ram. Permit 3.4.4: IDDE Tracking Ref. Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was observed, the results of the investigation, any follow-up of the investigation, the date the investigation was closed, the issuance of enforcement actions, and the ability to identify chronic violators. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 25. Track and document investigations of illicit discharges For each case the City of Lowell shall 1. Keep a spreadsheet of 1. Continuously in 1. Document total ff of track and document 1) the date(s) the stormwater ID calls, Permit Year I FY 21/22 submissions, resolutions, illicit discharge was observed; 2) the online submissions, and and the length in results of the investigation; 3) any emails. between. follow-up of the investigation; and 4) YIN/Status the date the investigation was closed. 2. Identify hotspot areas 2. Continuously in 2. Y/N/Status see BMP No. 23 Permit Year 1 FY 21/22 Permit 3,4.5: Staff IDDE Training Ref. Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities, may observe an illicit discharge, illicit connection, illegal dumping or spills. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping and spills. Each staff training event shall be documented, including the agenda/materials, date, and number of staff participating. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 26. Provide Employee Training DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 26 Table 1.5: Illicit Discharge Detection and Elimination BMWs The permittee shall implement and 1. Begin a quarterly 1. Begin in Permit Year 1. Report number of staff document a training program for training program for 2 FY 22123 trained appropriate municipal staff, who as Public Works staff to Quarterly part of their normal job identify and report illicit responsibilities, may come into discharge/SOP. contact with or otherwise observe an illicit discharge or illicit connection. (See the SOP BMP No. 21.2 27. Fact Sheets Hang fact sheet posters in employee 1. Create fact sheets for 1. Begin in Permit Year I. YIN/Status common areas to serve as a reminder illicit discharges. 2 FY 22123 of the basics on identifying and Once reporting illicit discharges, 2. Display posters in 2. Begin in Permit Year 2. Number of posters connections, and dumping. common areas. 2 FY 22123 hung Once Permit 3.4.6: IDDE Reporting Ref. Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained personnel. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 28. Stormwater Hotline The City of Lowell shall promote and 1. See BMP No. 11 1. See BMP No. 11 1. See BMP No. 11 maintain a stormwater hotlinelhelpline for the purpose of the public asking stormwater questions and re orting issues. 29. Stormwater Website The City of Lowell shall promote and 1. See BMP No. 10 1. See BMP No. 10 1. See BMP No. 10 maintain, an internet web site designed to convey the program's message. Other information included: the MS4 permit, SWMP, applicable ordinances, reporting mechanisms, educational materials, opportunities for involvement, and stormwater number. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 27 PART S: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153, the City of Lowell relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 and the NCG010000 permit for construction activities as qualifying alternative programs to meet the NPDES MS4 Permit requirements for all construction site runoff control measures to reduce pollutants in stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre and any construction activity that is part of a larger common plan of development that would disturb one acre or more. Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program al Meets Whole Reference State or Local Program Name Authority Implementing Entity or Part of Requirement 3.5.1 - Gaston County 15A NCAC Gaston County Whole 3.5.4 Delegated SPCA Program* Chapter 04 * The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at: https://www. towel li-ic.coi-n/DocumentCenter/View/75 I /S edimentation-and- Soil -Eras ion-Contro t- Ordinance In addition to the delegated SPCA Program, opportunities for public input through the stormwater hotline and additional waste management requirements for construction site operators complete the construction site run off control program. The City of Lowell also implements the following BMPs to meet NPDES MS4 Permit requirements. Table 17: Construction Site Runoff Control BMPs Permit 3.5.6: Public Input Ref. Measures to provide and promote a means for the public to notify the appropriate authorities of observed erosion and sedimentation problems. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting hn lementation Metric 30. Municipal Staff Training Train municipal staff who receive 1. Train municipal staff 1. Annually beginning in 1. Document and report calls from the public on the protocols on proper handling of permit Year 2 (FY number of staff trained, for referral and tracking of construction site runoff 22/23) training date(s) and construction site runoff control control complaints. topics covered. aint com ls. 31. Stormwater Hotline A hotline will be maintained for 1. See BMP No. 11 1. See BMP No. 11 1. See BMP No. 11 citizens to ask questions and report stormwater concerns. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 28 Table 17: Construction Site Runoff Control BMPs Permit 3.5.5: Waste Management Ref. Measures to require construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to water qualit . BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 32. Establish and Maintain Legal Authority Develop and implement an ordinance 1. Adopt ordinance 1. Permit Year 2 FY 1. Y/N/Status to require construction site operators 22/23 to control waste. Once 2. Maintain legal 2. Continuously, after 2. Y/N/Status authority ordinance is adopted, 33. Contractor Education Communicate new waste 1. Create fact sheets to 1. Permit Year 2 FY 1. YIN/Status management requirements to share during pre- 22/23 , after ordinance is contractors/construction site construction meetings adopted operators. Once 2. Add fact sheet to 2. Permit Year 2 FY 2. YIN/Status website 22/23 , after ordinance is adopted Once 3. Distribute fact sheet at 3. Permit Year 2 FY 3. Number of fact sheets pre -construction 22/23 , after ordinance is distributed meetings adopted Continuous DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 29 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM This SWMP identifies the minimum elements to develop, implement and enforce a program to address stormwater runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that are located within the City of Lowell and discharge into the MS4. These elements are designed to minimize water quality impacts utilizing a combination of structural Stormwater Control Measures (SCMs) and/or non-structural BMPs appropriate for the community, and ensure adequate long-term operation and maintenance of SCMs. In accordance with 15A NCAC 02H .0153 and .1017, the City of Lowell implements the following State post -construction program requirements, which satisfy the NPDES Phase H MS4 post -construction site runoff control requirements as Qualifying Alternative Programs (QAPs) in the MS4 area(s) where they are implemented. Table 18: Qualifying Alternative Program(s) for Past -Construction Site Runoff Control Program State QAP Name State Requirements Local Ordinance / Regulatory Mechanism Reference NA * The local delegated SPCA Program ordinances)/regulatory mechanism(s) can be found at: The City of Lowell has no existing requirements other than Qualifying Alternative Programs) for implementation of the NPDES Phase II MS4 post -construction program requirements. Table 19: Summary of Existing Post -Construction Program Elements DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 30 Permit Requirements for Municipal Ordinance/Code Reference(s) Date Adopted Plan Review and Approval and/or Document Title(s) 3.6.2(a) Authority Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-33 3.6.3(a) & 15A NCAC 0211.0153(c) Gaston County Stormwater Ordinance 09/06/2007 Federal, State & Local Projects Chapter 5.5-33 3.6.3(b) Plan Review Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-37 3.6.3(c) O&M Agreement Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-48 3.6.3(d) O&M Plan Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-40 3.6.3(e) Deed Gaston County Stormwater Ordinance 09/06/2007 Restrictions/Covenants Chapter 5.5-48 3.6.3(f) Access Easements Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-48 Permit Requirements for Municipal O.rdinance/Code Reference(s) Date Adopted Inspections and Enforcement and/or Document Title(s) 3.6.2(b) Documentation Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-39 3.6.2(c) Right of Entry Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-45 3.6.4(a) Pre -CO Inspections Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-45 3.6.4(b) Compliance with Plans Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-45 3.6.4(c) Annual SCM Inspections Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-48 3.6.4(d) Low Density Inspections Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-37 3.6.4(e) Qualified Professional Gaston County Stormwater Ordinance 09/06/2007 Chapter 5.5-39,48 Permit Requirements for Municipal Ordinance/Code Reference(s) Date Adopted Fecal Coliform Reduction and/or Document Title(s) 3.6.6 a Pet Waste See BMP No. 39 3.6.6(b) On -Site Domestic City of Lowell Sewer Use Ordinance — WastewaterTtreatment Section 6.7 a- Private Sewage Disposal DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 31 The annual reporting metrics for the post construction program are provided in Table 20: Post Construction Site Runoff Control BMPs below. Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post -Construction Reporting Requirements Ref. Measures to document activities over the course of the fiscal year (July 1 — June 30) including appropriate information to accurately describe rogress, status, and results. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting 1m lementation Metric 34. Standard Reporting Implement standardized tracking, 1. Track number of low 1. Continuously 1. Number of plan documentation, inspections and density and high density reviews performed for reporting mechanisms to compile plan reviews performed. low density and high appropriate data for the annual self density. assessment process. Data shall be 2. Track number of low 2. Continuously 2. Number of plan provided for each Post -Construction/ density and high density approvals issued for low Qualifying Alternative Program plans approved. density and high density. being implemented. 3. Maintain a current 3. Continuously 3. Summary of number inventory of low density and type of SCMs added projects and constructed to the inventory; and SCMs including SCM number and acreage of type or low density low density projects acreage, location and last constructed. inspection date. 4. Track number of SCM 4. Continuously 4. Number of SCM inspections performed. inspections. 5. Track number of low 5. Continuously 5. Number of low density density inspections inspections. performed. 6. Track number and 6. Continuously 6. Number and type of type of enforcement enforcement actions actions taken. taken. Permit 2.3 and 3.6: Qualifying Alternative Program(s) Ref. Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state program re uirementS. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 35. NA DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 32 Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.2: Legal Authority Ref. Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review designs and proposals for new development and redevelopment to determine whether adequate stormwater control measures will be installed, implemented, and maintained, (b) request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post -Construction Stormwater Management Program, and (c) enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater discharges to determine whether there is compliance with the Post -Construction Stormwater Management Program. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 36. This permit requirement is fully met by the existing post -construction program, see references provided in Table 19. 37. Amend Interlocal Agreement Amend the interlocat agreement Amend the interlocal Permit Year 1 Yes/No Status? between City of Lowell and Gaston agreement and then County for allowing the City of implement BMP No. 34. Lowell to provide City -Specific numbers for MS4 Permit requirements. Permit 3,6,3: Plan Review and Approval Ref. Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal, State, and local government projects to comply with Post -Construction Program requirements throughout the entire MS4 pernutted area, unless the entity is subject to its own NPDES MS4 permit or a qualifying alternative program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that complies with 15A NCAC 02H. 1050(12), (d) Ensure that each project has an Operation and Maintenance Plan that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A NCAC 02H 1050 9 and (10). BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 38. This permit requirement is fully met by the existing post -construction program, see references provided in Table 19 DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 33 Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.4: Inspections and Enforcement Ref. Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post - construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy. Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s), (b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (c) Require that inspections be conducted by a qualified professional. BMP A B C D No, Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 39. This permit requirement is fully met by the existing post -construction program, see references provided in Table 19 Permit 3.6.6: Fecal Coliform Reduction Ref. Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H .1017(7). At a minimum, the program shall include. (a) A pet waste management component, which may be achieved by revising an existing litter ordinance, and (b) An on -site domestic wastewater treatment system component, if applicable, which may be coordinated with local county health department, to ensure proper operation and maintenance of such systems. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 40. Pet Waste Litter Program Revise the City of Lowell Code of 1. Develop text 1. Permit Year 1 FY 1. Completed? Ordinances Chapter 94 (Litter) to amendments for pet 21/22 Y/N/Partial include pet waste disposal criteria. waste disposal Once requirements. 2. Include information in 2. Permit Year 2 FY 2. Completed? city newsletter for 22/23 Y/N/Partial reference of change. Once DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 34 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City of Lowell municipal facilities and operations. Pollution prevention and good housekeeping is accomplished through the implementation of seven required programs, which collectively address the ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and open space maintenance, fleet and building maintenance, new construction and land disturbances, and municipal storm sewer system maintenance. Pollution prevention and good housekeeping for municipal operations includes the following programs: 1. Municipal Facilities Operation and Maintenance Program 2. Spill Response Program 3. MS4 Operation and Maintenance Program 4. Municipal SCM Operation and Maintenance Program 5. Pesticide, Herbicide and Fertilizer Management Program 6. Vehicle and Equipment Maintenance Program 7. Pavement Management Program The spill response program resides with the Public Works Department, but we will look to collaborate with the Lowell Volunteer Fire Department. The rest of the pollution prevention and good housekeeping also resides within the Public Works Department. The City provides leaf collection between October 16- February 15 and will continue to track the volume of debris collected. Initially an inventory of all municipal facilities will be completed to serve as a basis for developing the program and creating documentation for inspections. The City of Lowell will manage, implement and report the pollution prevention and good housekeeping BMPs as specified in Table 21 below for each required program. Table 21: Pollution Prevention and Good Housekeeping BMPs Permit 3.7.1: Municipal facilities Operation and Maintenance Program Ref. Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities; perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on general stormwater awareness and imp menting.pollution prevention and Rood housekeeping ractices. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 41. Inventory of municipally owned or operated facilities. Maintain a current inventory of City 1. Create a list of 1. Permit Year 1 FY 1. Number of facilities facilities that have the potential of existing facilities 21/22 inventoried; date list is Continuous completed DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 35 Table 21: Pollution Prevention and Good Housekeeping BMPs generating polluted stormwater 2. Perform facility 2. Permit Year 2 FY 2. Number of runoff. inspections and 22/23 inspections completed determine the potential to Annually and the number of generate polluted runoff facilities classified as or requiring spill high, medium, and low response procedures. potential. Further classify facilities as having high, medium, or low potential for stormwater runoff. 3. Identify and permit 3. As required 3. Number of facilities subject facilities no later continuous identified as required to than July 31, 2021 have NPDES Permit. 4. Determine which 4. Permit Year 2 FY 4. Number of SPCC facilities require a SPCC 22/23 Plans required. Plan. Once 5. Update inventory as 5. As required 5. Number of facilities needed when facilities Continuous added/changes made are added or closed. 42. Inspection of City Facilities Inspect City facilities to ensure 1. Create a SOP for 1. Permit Year 2 FY 1. YIN/Status good housekeeping practices are inspection of City 22/23 being followed. facilities, including Once inspection forms, frequencies, and report documentation. 2. Implement annual 2. Annually conduct 2. Number of inspections inspections for high inspections, beginning in of high, medium, and stormwater pollution Permit Year 3 FY 23/24 low potential facilities potential, once every two performed. years inspections for medium stormwater pollution potential, and once every permit term for low stormwater pollution potential facilities. 43. Staff Training 1. Develop and perform a 1. Permit Year 2 FY 1. Report number trained staff training program for 22/23 general stormwater Continuous pollution prevention and provide to public works employees. Permit 3.7.2: SpiEl Response Program Ref. Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response procedures. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 36 Table 21: Pollution Prevention and Good Housekeeping BMPs $M, A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Im lementation Metric 44. Spill Response Procedures for municipally owned or operated facilities. Maintain written spill response 1. See BMP No. 34 1. See BMP No. 34 1. See BMP No. 34 procedures and locations for Keep manual of municipal facilities that store procedures at all materials that would be classified as a facilities for inspection. hazard to the stormwater system if 2. Train municipal staff 2. Annually 2. Report number spilled. on the spill response. trained. 3. Update as facilities 3. Continuously, As 3. Number of additions and operations are required or revisions made revised. 4. Train Lowell VFD on 4. Annually 4. Report number of spill response. VFD staff trained 45. Staff Training Train staff at every municipal facility 1. See BMP No. 34 1. See BMP No. 34 1. See BMP No. 34 of where potential spills need to be isolated (location), what protocols to follow after spills, and preventative maintenance to avoid pollution. Permit 3.7.3: MS4 Operation and Maintenance Program Ref. Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections, maintain the collection system including catch basins and conveyances; and establish specific frequencies, schedules, and standard documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 46. Staff Training Develop and identify a staff training 1. Develop appropriate 1. Permit Year 2 FY I. YIN/Status program for general stormwater training program 22/23 pollution prevention and provide to Once public works employees 2. Provide initial training 2. Permit Year 3 FY 2. Number of staff for all employees 23/24, Annually members trained and topics. 3. Provide training for 3. Permit Year 3 FY 3. Number of new hires new hires 23/24, Annually, as and topics trained. necessitated by new hires 47. Operation and Maintenance (O&M) for municipally owned or operated facilities. Maintain and implement an 1. Develop appropriate 1. Permit Year 2 1. YIN/Status Operation and Maintenance (O&M) training program for program for municipal facilities that conducting collection specifies the frequency of inspections inspections and maintenance DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 37 Table 21: Pollution Prevention and Good Housekeeping BMPs and maintenance requirements of all 2. Create a collection 2. Permit Year 2 FY 2. Yes/No/Status? municipally owned facilities. system inspection 22/23, Annually document 3. Perform regular 3. Permit Year 2 FY 3. Report number of inspections of the 22/23, Annually inspection documents collection s stems submitted. Permit 3.7.4: Municipal SCM Operation and Maintenance Program Ref. Measures to manage municipally -owned, operated, and/or maintained structural SCMs that are installed for compliance with the permittee's post -construction program. The permittee shall maintain a current inventory of SCMs, perform SCM ins ections and maintenance, and shall establish specific frequencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 48. Identify and map for municipally owned or maintained structural stormwater controls Maintain a current inventory of 1. Document and map all 1. Permit Year 3 FY 1. Number of municipal municipally owned or operated municipal SCMs (year 23/24 SCMs. structural stormwater controls built, type, date of last Continuous installed for compliance with the inspection, and permitee's post -construction maintenance actions). ordinance. 2. Update MS4 map to 2. Permit Year 3 FY 2. Completed? reflect municipal SCMs. 23/24; Continuous Y/N/Partial 3. Compile and develop 3. Permit Year 4 FY 3. Completed? O&M Plans for all City- 24/25; Once Y/N/Partial owned SCMs. 4. Update as needed by 4. As required 4. Number of updates new City SCMs Continuous developed. 49. Operation and Maintenance for municipally owned or maintained catch basins and conveyance systems. Implement and O&M Program for 1. Inventory all 1. Permit Year 3 FY 1. Report date inventory stormwater system catch basins and municipal SCMs (year 23/24 completed and number of conveyance systems that it owns and built, type, date of last Once; After mapping structures inventoried maintains. inspection, and completed. maintenance actions). 2. Obtain NC SCM 2. Permit Year 4 FY 2. Number of staff Inspections and 24/25 members with active Maintenance Continuous certification Certification for personnel 3. Develop SCM 3. Permit Year 4 FY 3. Completed inspection form 24/25 YIN/Status Once 4. Inspect basins and 4. Permit Year 5 FY 4. Number of SCMs systems annually to 25/26 maintained determine condition and Annually recommend any relevant maintenance. DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 38 Table 21: Pollution Prevention and Good Housekeeping BMPs 5. Perform Maintenance 5. As required; 5. Number of SCMs tasks identified in Continuous maintained inspections Permit 3.7.5: Pesticide, Herbicide and Fertilizer Management Program Ref. Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine pollution prevention and chemical use, storage and handling training, and shall ensure compliance with permits and a licator certifications. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 50. Pesticide, Herbicide and Fertilizer Application Management and Training Ensure all municipal employees and 1. Maintain core, right- 1. Continuously 1. Document training by contractors are properly trained and of -way, and ornamental any staff that applies all permits, certifications, and other pest control applicator fertilizers or pesticides, measures for applicators are certifications continuing education and followed. keep up to date the applicator license from NC. 2. Develop or identify 2. Permit Year 2 FY 2. Y/N/Partial pollution prevention and 22/23 chemical use, storage Once and handling training program 3. Provide staff training 3. Permit Year 3 FY 3. Number of staff in pollution prevention 23/24, Annually trained and topics and chemical use, covered storage and handling training 4. Require City 4. Continuously 4. Y/N/Partial contractors to provide Number of contractors NC Pesticide License for that provided license inspection. 5. Implement training 5. Permit Year 3 5. Report number of program. certified personnel Permit 3.7.6: Vehicle and Equipment Maintenance Program Ref. Measures to prevent and minimise contamination of stormwater runoff from areas used for municipal vehicle and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution prevention training to staff, perform routine inspections, and establish specific fre uencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 51. NPDES Industrial Permit Compliance DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 39 Table 21: Pollution Prevention and Good Housekeeping BMPs Ensure NPDES industrial permit 1. Review municipal Permit Year 1 FY 21/22 Number of facilities compliance occurs at all applicable facilities inventory to Once required to have NPDES municipally owned sites. determine which Permit facilities require a NPDES permit and ensure they have before July 31, 2021 2. Permitting of Permit Year 1 FY 21/22, Report number of municipally owned after review of facilities, new/active/existing facilities before July 31, and continuously permits 2021. thereafter 3. Develop a municipal Permit Year 1 FY 21/22 Y/N/Status industrial facility Once —inspections form 4. Perform facility Permit Year 2 FY 22/23 Number of inspections inspections for NPDES Annually performed Permit 5. Create NPDES Permit Permit Year 2 FY 22/23 5. YIN/Status tracking mechanism to Once document list of facilities owned with permit, expiration dates, and ins ections 52. Vehicle and Equipment Cleaning Maintenance Facility Inspection Routine inspections to ensure that the 1. Develop an inspection 1. Permit Year 1 1. YIN/Status facilities are following proper checklist FY/21/22 procedures to minimize water quality Once impacts from vehicle and equipment cleaning and maintenance. 2. Perform inspections using checklist and 2. Permit Year 2 FY 22/23 Annually 2. Number of inspections notify public works of any corrective actions 3. Reinspect any 3. As required 3. How many corrective corrective action actions, number of situations resolutions Permit 3.7.7: Pavement Management Program Ref. Measures to reduce pollutants in 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 ollutants associated with vehicles, and establish specific frequencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 53. Streets, roads, and public parking lots maintenance/sweeping/leaf collection Lowell shall evaluate existing and 1. Develop a SOP with a 1. Permit Year 1 FY 1. Y/N/Partial new BMPs annually that reduce schedule of leaf 21/22 polluted stormwater runoff from collection, gutter Once municipally -owned streets, roads, and blowing, and street public parking lots within their cleaning with a plan to corporate limits. The permitee must I document DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 40 Table 21: Pollution Prevention and Good Housekeeping BMPs evaluate the effectiveness of these 2. Implement SOP and 2. Permit Year 2 FY 2. Report volume of BMPs based on cost and the documentation 22/23 leaves collected and estimated quantity of pollutants Once and then roads removed. Continuously after implementation 54. Vehicle/Equipment Spill Cleanup An organized vehicle and equipment 1. See BMP No. 43 1. See BMW No. 43 1. See BMP No. 43 spill cleanup response to prevent 2. Provide S ways you 2. See BMP No. 10 2. See BMP No. 10 pollutants from vehicular accidents or equipment failures from entering the can help flyers to new stormwater system. utility customers (BMP No. 10) DRAFT NCS000444 SWMP City of Lowell January 13, 2021 Page 41