HomeMy WebLinkAboutNCS000430_Montreat MS4 Renewal Application_202202010"WE
NPDES MS4 Permit Application Form
National Pollutant Discharge Elimination System (NPDES)
Municipal Separate Storm Sewer System (MS4)
Please complete the information below and submit this form along with the required supplemental information
to the address indicated.
Part I: Permittee Information
Current Permit No.
NCS000430
Name
RE15SIVEDMS4
Town of Montreat
Owner Name*
Timothy R. Helms FEB 01 2022
Owner Title
Mayor
Street Address
507 South Carolina Terrace STORMWATERPERMI7IIN�
City, State Zip
Montreat NC 28757
Phone Number
828-669-3852
E-mail Address
timmybob.566@gmail.com
* The owner must be a princlpal executive officer or ranking elected official for the city/town/entity that
owns/operates the permitted M54. Any permit enforcement actions will be sent to the owner on record.
Part II: Primary Contact**
Contact Name
Barry Creasman
Contact Title
Public Works Director
Employer
Town of Montreat
Street Address
PO Box 423
City,State Zip
Montreat NC 28757
Phone Number
828-669-8002 ext. 3040 _
I bcreasman@townofmontreat.or
E-mail Address
** The primary contact Is the responsible party who will oversee the day-to-day permit compliance and
StormwaterManagement Program implementation. With the exception of enforcement actions, permit
communications originating from NCOEQ will be sent to the primary contact and will be copied to the other
contacts /fisted below.
Part III: Other Contacts
Contact Name
Angie Murphy
E-mail Address
amurphy@townofmontreat.org
Contact Name
Mary Roderick
E-mail Address
mary@landofsky.org
PartIV: Required Supplemental Information
Submit one (1) hard copy and one (1) electronic copy of a Draft Stormwater Management Plan (SWMP)
with this permit application. The Draft SWMP must be in the current NCDEQ SWMP Template format
and shall include all required information in order for the permit renewal application to be considered
complete.
Page 1 of 2
Part V: 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 incomplete permit renewal
applications, inclusive of the required Draft SWMP, will not be processed and will be returned to the
permittee.
I am a ranking elected official for the permitted MS4.
❑ I am a principal executive officer for the permitted MS4.
O I am a duly authorized representative for the permitted MS4 and have attached the authorization
made in writing by the permit owner listed in Part I of this application, which specifies me as (check
one):
O A specific individual having overall responsibility for the stormwater permit.
O A specific position having overall responsibility for the stormwater permit.
Signature:*
Print Name:
f m �fw,g
Title:
Allftvoia—
Signed this �ZI day of 20_22,
Please note that an orb/signature is required on this form, any required supplemental information, and any
representative authorization. Photocopies cannot be accepted.
Return this completed form along with the required supplemental information to:
DEQ-DEMLR Stormwater Program
Attn: MS4 Permitting
1612 Mail Service Center
Raleigh, NC 27699-1612
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NPDES RPE Stormwater Permit Application
Town of Montreat
Comprehensive Stormwater Management Program Report
November1, 2016
Table of Contents
Part 1. Storm Sewer System Information
Page 3
Section 1.1 Population Served
Page 3
Section 1.2 Growth Rate
Page 3
Section 1.3 Jurisdictional and MS4 Service Areas
Page 3
Section 1.4 MS4 Conveyance System
Page 3
Section 1.5 Land Use Composition Estimates
Page 3
Section 1.6 TMDL Identification
Page 4
Part 2. Receiving Streams
Page 5
Part 3. Existing Water Quality Programs
Page 6
Section 3.1 Local Programs
Page 6
Section 3.2 State Programs
Page 7
Part 4. Permitting Information
Page 8
Section 4.1 Responsible Party Contact List Page 8
Section 4.2 Organizational Chart Page 8
Section 4.3 Signing Official Page 9
Section 4.4 Duly Authorized Representative Page 9
Part 5. Co -Permitting Information (Not Applicable)
Page 9
Part 6. Reliance on Other Government Entity
Page 10
Part 7. Stormwater Management Program
Page 11
Section 7.1 Public Education and Outreach
Page 11
Section 7.2 Public Involvement and Participation
Page 15
Section 7.3 Illicit Discharge Detection and Elimination
Page 17
Section 7.4 Construction Site Stormwater Runoff Control
Page 22
Section 7.5 Post -Construction Stormwater Management
Page 22
Section 7.6 Pollution Prevention/Good Housekeeping
Page 27
Duly Authorized Representative Designation
Appendix A: SCM Summary Table
Appendix B: Town of Montreat Stormwater Management Ordinance
Appendix C: Buncombe County Soil Erosion and Sedimentation Control Ordinance
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Town of Montreat
Comprehensive Stormwater Management Program Report
November 1, 2016
Part I. Storm Sewer System Information
Section 1.1 Population Served
The Town of Montreat has a permanent population of approximately 792 based on recent
numbers from the State of North Carolina Data Center and local figures. During the months of
May, June, July and August the seasonal population increases to over 12,000 based on
information provided by the Montreat Conference Center for conference attendees.
Section 1.2 Growth Rate
A population count of 723 from the 2010 census, contrasted with the more recent data
indicates just over a 1 % annual growth rate.
Section 1.3 Jurisdictional and MS4 Service Area
Certification for Powell Bill funding indicates total mileage of participating roadways to be 15.23
miles. Total Jurisdictional and MS4 service area is calculated at approximately 3.87 square
miles for the Town.
Section 1.4 MS4 Conveyance System
The MS4 conveyance system for the Town consists of a combination of culverts ranging from
12" to 72" in size, French drains, catch basins, open swales and ditches, and one dry lake.
Routine maintenance involves regular inspection and cleaning of culverts and catch basins,
and closely monitoring performance of these systems and their effectiveness during and
following storm events. One engineered stormwater detention system has been added within
the last three years with scheduled maintenance performed as required by the system
designer. All conveyance systems within the corporate limits are owned and maintained by the
Town, with no state-owned roads present within ourjurisdiction.
Section 1.5 Land use Composition Estimates
The Town of Montreat is primarily a residential community, with no commercial tax base or
industrial development. Montreat Conference Center, the founding non-profitentity with in the
Town, is one of three national conference centers affiliated with the Presbyterian Church USA,
annually visited by over 35,000 people. The Town is also home to Montreat College, a
Christian liberal arts college offering masters, bachelors, and associate's degrees. The Board
of Commissioners adopted the Town of Montreat Comprehensive Land Use Plan in 2008,
along with the Open Space Conservation Plan (OSCP). The primary focus of the OSCP is to
enhance the Town's ability to protect lands with high natural resource value. More specifically,
the Plan aims to:
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• provide the strategies, plans, and guidance thatwill realize the Town's long-term vision
for con servi n g i mportant open spaces an d n atu ral resou rces;
• establish a ranking system to set priorities for use when evaluating properties in the
Town for conservation;
• inform the public on open space and land conservation issues, policy, process and
plans;
• enhance public awareness about the benefits derived from - and threats posed to -
Montreat's diverse natural resources; and
• establish and guidethe useof the Town'sConservation Fund.
There are currently approximately 175 remaining platted, undeveloped lots in Montreat,
with more than 60% of the jurisdictional land held in conservation (protected open space)
easement. Due to the highly residential composition of the Town, the greatest
concentration of impervious cover is localized within the Town Cen ter area wh ere th a larger
institutional -use buildings and parking owned by Montreat Conference Centerand Montreat
College are located.
Section 1.6 TMDL Identification
The Town is currently not under EPA or NCDENR authority for Total Maximum Daily Load
(TMDL) allocation for discharges into controlled body of water [requirements] or receiving
streams.
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Part II. Receiving Streams
The Town of Montreat is located within the French Broad River Basin.
Table 1. French Broad River Basin
Receiving
Stream
Water Quality
Use Support
Water
Stream
Segment
Classification
Rating
Quality
303(d) List
Name
Issues
Flat Creek
Headwaters
C, HQW
Supporting
None
Id entif ied
NIA
Big Piney
Upper NW
None
Branch
Comer into
C, HQW
Supporting
Identified
NIA
Flat Creek
South of
Kitchen
Sourwood
C
Supporting
None
NIA
Branch
Gap into Flat
Identified
Creek
West Lower
Un-named
Area below
Unrated
Supporting
None
NIA
Tributaries
Little Piney
Identified
Branch
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Part III. Existing Water Quality Programs
Section 3.1 Local Programs
Comprehensive Land Use Plan — Adopted in April of 2008, the Comprehensive Plan is one
step toward ensuring that new development and the infrastructure and services that
accompany it help Montreat remain a tranquil town, while much of the natural environment
remains intact. The plan is a reflection of the community's desires and serves as a policy
guide that will aid decision makers over the coming years. The plan outlines goals and
proposes regulations that protect and improve water quality, safeguard human health, protect
aquatic habitats and encourage stewardship and pollution prevention within Montreat.
Open Space Conservation Plan — Adopted in 2007, the primary focus of the Open Space
Conservation Plan is to enhance the Town's abilityto protect lands with high natural resou rce
value. More specifically, the Plan aims to:
• provide the strategies, plans, and guidance that will realize the Town's long-term vision
for conserving important open spaces and natural resources;
• establish a ranking system to set priorities for use when evaluating properties in the
Town for conservation;
• inform the public on open space and land conservation issues, policy, process and
plans;
• enhance public awareness about the benefits derived from - and threats posed to -
Montreat's diverse natural resources; and
• establish and gu ide th a use of the Town's Conservation Fund.
Stormwater Management Regulations — The Town of Montreat has adopted Stormwater
Management regulations that require application for approval and permitting of projects as
small as 5,000 square feet disturbed area, 24% total lot area developed to include impervious
cover, or addition of 2,500 square feet impervious surface. Details of the new regulations can
be found in Section 7.5 of this report.
Flood Damage Prevention Ordinance — Based upon the State model, the Flood Damage
Prevention Ordinance and associated Flood Insurance Rate Maps became effective January
6, 2010. The Ordinance requires enforcement of increased riparian buffer widths around
streams with no established Base Flood Elevations.
Hillside Development Ordinance — During the summer of 2009, the Town adopted a Hillside
Development Ordinance that contains provisions requiring detailed geotechnical site
assessments for steeply -sloping lots, and establishes guidelines that limit the amount of site
disturbance and impervious cover that may be introduced; ultimately, with the goal of reducin g
the overall potential negative impacts to the surrounding watershed through decreased site
instability and erosion.
Erosion and Sedimentation Control — The Town continues to enforce Buncombe County
Erosion and Sedimentation Control permitting requirements for land -disturbing activities
greater than one acre.
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Street Standards Ordinance — Recently amended street standards for the Town include
language encouraging the use of Stormwater Control Measures (SCM's) wherever practicable,
to minimize additional impervious cover and include provisions for narrower lanes to service
lower traffic volu me areas.
Building Code Amendments —The Town has amended building regulations within the Gen eral
Ordinances to include financial incentives for developers and builders that utilize Low Impact
Development (LID) practices for projects; hire approved Clear Water Contractors to conduct
site grading; incorporate stormwater or graywater collection/recycling systems; or pursue
LEED, Green Globe, NAHB Green Home, or other state or nationally recognized third -party
certification for "Green" site development and building practices.
Section 3.2 State Programs
The Town of Montreat has no existing programs that are implemented by the state within the
MS4 service area.
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Part IV. Permitting Information
Section 4.1 Responsible Party Contact List
Measurable
Name
Position
Telephone
Fax
E-Mail
Goal
Sections 7.1
Al
(Interim) Town
(828) 669-8002
(828) 669-3810
aichardson@townofmontreat.org
and 7.6
Richardson
Administrator
Sections 7.1;
Code
Administrator/
7.2; 7.3; 7.4;
David Currie
Building
(828) 669-8002
(828) 669-3810
dcurrie@townofmontreat.org
7.5; and 7.6
Inspector
Sections 7.1;
Steve
Public Works
7.2; 7.3; and
Freeman
Director
(828) 669-8002
(828) 669-3810
sfreeman@townofmontreat.org
7.6
See Sections
for Specific
Responsibilitie
s
Section 4.2 Organizational Chart
Town of Montreat
Board of
Commissioners
Boardsand
Commissions Town Administrator Town Attorney
Town Clerk 1 I Public Works Director 1 I Finance Officer 1 I Police Chief
Utility Maintenance
Technicians/Operators
Utility Maintenance
Workers
Building
Inspector/Code
Administrator
Police Officers
Auxiliary Police
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Section 4.3 Signing Official
The signing official forthe Town of Montreat is David Currie, the duly authorized
representative. David Currie serves as the Code Administrator/Building Inspector and has
oversightand responsibility over stormwater matters. Mr. Curriewas unanimously appointed
as the Town's authorized representative for the National Pollutant Discharge Elimination
System Permit on February 11, 2010.
Section 4.4 Duly Authorized Representative
The Town of Montreat Board of Commissioners appointed David Currie as the Town's
authorized representative to apply for the National Pollutant Discharge Elimination system
permit. Mr. Currie serves as the Code Administrator/Building Inspector and has oversight and
responsibility over stormwater matters. Written authorization from Mayor Tim Helms is
submitted along with the Stormwater Management Program Plan.
Part V. Co -Permitting Information (Not Applicable)
The Town of Montreat is not working with another MS4 or grou p of MS4s to develop and
implementthe Phase II stormwater program within ourjurisdictional area.
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Part VI. Reliance on other Government Entity to Satisfy One or More Permit
Obligations
The Town of Montreat relies on the following government entities to satisfy one or more permit
obligations and is not applying as co-permittees:
Sedimentation and Erosion Control:
Buncombe County Planning Department
Erosion and Sedimentation Control Program
Mr. Doug Sharp
Buncombe County Planning Department, 46 Valley Street, Asheville NC 28801
Telephone Number: (828) 250-4848
A legal agreement is in place establishing the relationship between the County and the
Town for administration of this program.
Hazardous Materials:
North Carolina Hazardous Materials Regional Response Team
Asheville Fire Department
P.O. Box 7148, Asheville NC 28802
Telephone Number: (828) 259-5636
Statutory authority is in place for the RRT to respond to emergencies in Montreat
through the Black Mountain Fire Department.
Public Education Assistance (in addition to Town Educational Initiatives):
Land -of -Sky Regional Council
Mr. Bill Eaker
Environmental Services Director
339 Leicester Highway, Suite 140, Asheville, NC 28806
Telephone Number: (828) 251-6622
Montreat is a member of the Regional Council of Governments and participates in the
regional initiative to produce public information on stormwater management.
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Part VII. Stormwater Management Program Plan
The goals of this Storm Water Management Program (SWMP) Plan are to:
1. Reduce the discharge of pollutants from the municipal separate storm sewer system
(MS4) to th a maxi mu m exten t practicabl e;
2. Protect water quality; and
3. Satisfy the appropriate requirements of the Clean Water Act.
This SWMP contains the actions to betaken to effectively develop and implementthe six
(6) required Phase II measures within Montreatand effectivelyfulfill the above stated program
goals. Included in this SWMP Plan are the Stormwater Control Measures (SCMs) that will be
used to fulfill program requirements, frequency of each SCM, measurable program goals,
implementation schedule, and responsible positions. AppendixA provides a summary of all
these SCMs. Staff of the Town of Montreat underthe direction of the Town Administrator is
responsible forthe fulfillmentof all activities discussed in this SWMP. The development and
implementation of this SWMP will be completed within five (5)years from the effective date of
the issued NPDES Permit.
Section 7.1 Public Education and Outreach on Storm Water Impacts
The Town of Montreat has developed and implemented a publiceducation programto
distribute educational materials to the community and conduct outreach activities focused on
the impacts of storm water discharges on waterbodies and the steps that the public can take to
reduce these impacts and protect water quality conditions. The following Sections explain the
SCMs implemented to meet these requirements, audience and pollution sources thatwill be
targeted, outreach strategy, decision process and measures of success.
Target Pollutants
Sedimentation continues to be ourprimary target pollutant source and the reason our program
directs educational resources to our local development community. We have also developed
materials that teach residents to be aware of run-off pollutants from yards and streets and the
importance of keeping drains and ditches free of debris. Lawn care activities, illicit
connections, improper disposal and poor housekeeping are pollution sources targeted for
addressing as part of the public education program in Montreat.
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SCM Summary Table for the Public Education and Outreach Program
rS_CM
measurable' Goals
YR
Y
TM
Y. ,
�(R
YR
Resphonsible:
`Position;;
1.
Implement
Provide to the publican annual
X
X
X
X
X
Code
Education
stormwater report that targets a
Administrator
and
specific storm water problem and
Outreach
actions that can be taken to reduce
Program
water quality impacts.
Town
Distribute regional and local pollution
X
X
X
X
X
Administrator
prevention brochures and educational
and Code
materials at special events and in the
Administrator
town services building.
Maintain stormwater informational
X
X
X
X
X
Code
web page on the Town of Montreat
Administrator
website.
Advertise LID Workshops for
X
X
X
X
X
Code
Builders/Developers in conjunction
Administrator
with the Town's regional partners.
Advertise Clear Water Contractors
X
X
X
X
X
Code
Certification Course in conjunction
Administrator
with the Town's regional partners.
Stencil or label new storm drains to
X
X
X
X
X
Public Works
prevent illicit discharge
Director
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Target Audience
The target audiences forth public education program include those entities within Montreat
that will have significant positive and/or negative impacts on water quality conditions. The
audiences selected are listed below along with an explanation as to why they are being
targeted for educational outreach.
General Public: The general public has been selected as a target for the educational program
due to the significant negative impacts they can have on water quality conditions including
dumping oil and otherwastes into storm drains, improper disposal of household hazardous
wastes, improper disposal of yard wastes along creek banks and improper application of
pesticides and herbicides on lawns. The general public has also been targeted due to the
significant positive impacts they can have on water quality including reporting pollution
problems observed in streams. The general public has also been targeted due to their
potential to provide significant volunteer hours for improving/protecting water qualitythrough
participation in the stream clean-ups, landcare initiatives and storm drain marker programs.
Developers: Developers have been targeted due to their potential to cause negative impacts
to water quality from activities such as improper handling of waste and poor housekeeping
measures as it relates to construction sites and sedimentation control.
Institutional: Institutional facilities have been targeted due to their potential to cause negative
impacts to water qualityfrom activities such as improper handling of waste, illicit discharges
and poor housekeeping measures. Some specific institutional facilities that have been
targeted include: Montreat College and the Montreat Conference Center. Our target audience
consists of the large non -profit entities based in Montreat, homeowners, and the development
commu n ity.
Outreach and Decision -Making Methodology
The Town participated in a regional work group convened by Land -of -Sky Regional Council to
develop Public Service Announcements, brochures, and website information. Locally, we
provide this information to the public and the development commu n ity through the Town's
Inspection Department and on ourTown website. The outreach strategy will include the
following mechanisms:
Printed Brochures: This outreach mechanismwill be used to target specific pollution sources
associated with the general public, institutional facilities and developers. Brochureswill be
distributed during responses to citizen requests for service, inspections and atevent displays.
Brochures will also be developed to increase public involvement in water quality volunteer
initiatives such as the annual stream clean-ups, landcare initiatives and storm drain marker
programs as well as to increase public reporting of pollution problems. This information will be
distributed at event displays and when responding to citizen requests for service.
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NewspaperAds: As funding is made available to our regional partners, newspaperads will be
run in cooperation with LOSRC during the Spring and Fall of each calendaryear to target a
variety of water quality issues associated with the general public including proper lawn care
practices, proper disposal of household hazardous wastes and proper disposal of used oil and
other waste automotive products. The ads will also be used to encourage the reporting of illicit
connections, improper disposal and general water quality problems as well as to increase
involvementin volunteer activities. The ads will also be used to informthe general publicthat
they are not to be used for the disposal of waste products.
Media: As funding is made available to our regional partners, radio and television ads will be
run in conjunction with the regional stormwater initiative established by Land -of -Sky Regional
Council to target the general public, focusing primarily on the actions that citizens may take to
prevent negative water quality impacts. Participation in volunteer programs will also be
emphasized as part of this media campaign.
Web Page: A web page, developed during the first year of the permit, is directed at all the
target audiences including the general public and institutional entities. Specific information is
provided on these web pages directed at the pollution sources.
Educational Presentations: Educational presentations will continueto be given annually
targeted at the general public. These presentations will focus on the efforts necessary to
protect water quality and the promotion of volunteer activities and will be scheduled around the
summer conference season.
Staff Experience: OurTown Building Inspector continues to receive re -certification training as
a Stormwater BMP Reviewerand conducting StormwaterBMP Inspection and Maintenance,
and provides relevant instructional resourcesto the publicand consultation with developers
upon request.
Demonstration Sites: The Town has considered plans for additional demonstration sites to
provide an example of integrated stormwater managementfor infrastructure development.
Due to budgetary constraints and no currentfunding mechanism in place to explore these
activities, this phase of our program is on hold.
Evaluation
The measurable goals for each SCM are listed in the Table above. Other measures of
success for the public education program include the following:
1. Number of Citizen Requests for Service Received
2. Number of Water Quality Presentations Conducted
3. NumberofWebsite Inquiries
4. Number of Promotional Material Distributed
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Section 7.2 Public Involvement and Participation
Montreat has developed and implemented a Public Involvement and Participation Program to
provide opportunities forthe publicto participate in Phase II program development and
implementation.
SCM Summary Table for the Public Involvement and Participation
#.SCM
r
Measurable 'Goals
YR
YR
2
�YR
3.
YR
4�
YR,
5
Responsible
`Position
2
Involve the Public in
Annual presentations are made
X
X
X
X
X
Code
all program, permit
to the Governing Board at a
Administrator
and regulatory
public meeting concerning the
development
progress of the Phase II
program. As needed, additional
public meetings will be held to
receive comments/inputon all
proposed ch an ges to the
Stormwater Plan.
Maintain Storm Drain Marker
X
X
X
X
X
Public Works
Program
Director
Conductannual stream clean-up
X
X
X
X
X
Public Works
event
Director
Review and or revise
X
X
X
X
X
Code
Stormwater Ordinance as part of
Administrator
the Land Use Code updates by
Planning and Zoning
Commission and Town Council
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Public Involvement
The Town of Montreat encourages public participation in developmentof all land -use
regulations. Ourtarget audience forpublic participation isthe Town Planning and Zoning
Commission, Town Council, Mon treat Conference Center, Montreat College, as well as the
general public. To adopt the Phase II Ordinance, the Town appointed the Planning and Zoning
Commission as the Stormwater Advisory Group which assisted in drafting local regulations
based on a model ordinance provided by the Institute of Government. The Town Administrator
and chairman of the advisory group attended regional Stormwater Work Group meetings which
included representation from local developers, NCDWQ staff, a local environmental planning
firm, and regional municipal staff and citizen volunteers. As needed, this advisory committee
will be re -convened and coordinate efforts with community stakeholders should ourordinance
need to be updated or improved.
Volunteer Organizations
In addition to Town Committees and public process, Town staff works with local volunteer
groups including Montreat College, Warren Wilson College, Montreat Landcare and Buncombe
County Emergency Management, on stream and river clean-ups. The Town will continue to
involve the public in both ourgovernmental procedures and in supporting and promoting
volu nteer opportu n ities.
Community Partnerships
Recently, the Town attended stakeholder meetings to participate in developmentof the Upper
Swannanoa River Watershed Management Plan. Staff worked with the Town of Black
Mountain Planning Department, Warren Wilson College, NCDENR/DWR, Riverlink, Land of
Sky Regional Council, Equinox Environmental and local residents. The goal was to discuss
local watershed needs, prioritize specific destressed or at -risk areas and explore mitigation
approaches to protect our valuable water resources. We continue to explore opportunities to
partner with other local organizations in order to maximize the efficient use of every asset
available.
Measurable Goals
The decision process forthis SCM was based on the requirementsof the Phase II program,
the existing conditions in Montreatand ourbest judgmenton the most effective method to
achieve these goals. In the past 5 years of this program, we have been successful in meeting
all public involvement requirements through the passage of the Phase II rules and in working
with multiple volu nteer grou ps and organizations. Other measures of success for the public
involvement and participation include the following:
1. Number of Volunteer Hours
2. Number of Tons of Trash Removed
3. Number of Miles of Streams Cleaned
4. Number of Storm Drains Stenciled
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Section 7.3 Illicit Discharge Detection and Elimination
Montreat has developed, implemented and enforced a program to detect and eliminate illicit
discharges. The following Sections explain the SCMs implemented to meet this requirement.
SCM Summary Table for Illicit Discharge Detection and Elimination
se-
MeasurableGoals
YR.YR
Y
. YR '
4
YR
5
Responsible
Position
3
Implement and
Maintain a map of outFall locations of
X
X
X
X
X
Code Admin.
enforce plan to
the MS4 system into local receiving
and Public
detect and
streams
Works Director
eliminate Illicit
Discharges
Enforce illicit discharge rules as part
X
X
X
X
X
Code
of the adopted Phase II Stormwater
Administrator
Ordinance
Code Admin.
Inspect the MS4 periodicallyfor illicit
X
X
X
X
X
and Public
discharges.
Works Director
Investigate complaints of illicit
X
X
X
X
X
Code Admin.
discharges by the Public Works
and Public
Department and Code Administrator.
Works Director
AdministerTown Comprehensive
Stormwater Management Plan
X
X
X
X
X
Code
Administrator
Provide employees cross -training for
detecting and reporting elicit
X
X
X
X
X
Code
discharges
Administrator
Continue implementing a public
outreach program and public
X
X
X
X
X
Code
reporting mechanism
Administrator
System Map
With the help of Montreat College, the Town produced a map in 2005 of inlets and outfalls.
This information is updated annually as part of a developing Town Comprehensive Stormwater
Management Plan (CSMP). We are currently in the process of reformatting this data for
incorporation within ourGIS mapping software for the Town. Information indicating necessary
changes or modifications is collected during routine inspection and maintenance of the Town
stormwater sewer system through the Public Works Department, and any proposed additions
are subject to review and approval by the Town.
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NPDES RPE Stormwater Permit Application
Stormwater Management ordinance
The Town of Montreat adopted the Stormwater Management Ordinance in 2005 and revised
the ordinance in 2009. The Ordinancefound in Appendix B states that no person shall cause
or allowthe discharge, emission, disposal, you ring, or pumping directlyor indirectlyto any
stormwater conveyance, the waters of the State, or upon the land in mannerand amountthat
the substance is likelyto reach a stormwater conveyance orthe waters of the State.
Prohibited substances include butare not limited to: oil, anti freeze, chemicals, petfeces or
animal waste, paints, garbage, and litter, or any liquid, solid, gas, or other substance, other
than stormwater, provided that non-stormwater discharges associated with certain
activities are allowed, provided that they do not significantly impactwater quality. The
Ordinance goes on to detail procedural guidelines foridentifying illicit discharges and clearly
outlines prohibited practices resulting in negative waterquality impacts.
Enforcement
Town employees, especially those working in the Public Works Department and
Inspections/Code Administration Department receive training on the hazards of illicit
stormwater discharges and improper disposal of waste. The Code Administrator has
completed coursework in stormwater SCM inspection and maintenance offered as programs
developed through joint efforts by NCSU-BAE and NC Cooperative Extension. Our public
education program makes information about illicit discharges available to Montreat Conference
Centerstaff and attendees, Montreat College faculty and students, and the general public.
The Inspections Department coordinates efforts with the Public Works Department to quickly
identify alleged illicit discharges and investigate the source within twenty-four hours of alert,
with the Stormwater Management Ordinance providing detailed guidance forenforcement
procedures. These procedures also include guidelines on when a notice of violation isto be
issued and on the assessment of penalties.
Detection and Elimination
An effective illicitdischarge detection and elimination plan is essential to the success of the
program. Initially, the Town of Montreat searched for illicitdischarges as we created the outfall
map. By the second year of our program we had our ordinance in place, staff assigned to
investigate discharges and trained employees in our Public Works department to be vigilantfor
illicit discharges as they carry out maintenance activities for our streets and drainage facilities.
When an alleged illicitdischarge is detected, Town staff followsthe substance backto its
source using visual and olfactoryevidence as indicators. If necessary, the Town will use dye
to help establish the path of the discharge. Since Plan implementation, a numberof alleged
illicit discharges have been investigated — with all but one determined to be problems
associated with malfunctioning sewerlines, and the Metropolitan Sewerage District (MSD) of
Buncombe Countywas immediately notified to rectify the situation(s); consequently, MSD has
been consistently improving theirsystem within the Town, eliminating "dead ends" and
significantly reducing the volume of these nuisance discharge events each year. The isolated
non -sewer incidentwas determined to be discharge of potable water from a public water
supply source associated with a swimming pool back -flush system. No verifiable illicit
discharges have been identified since implementation of our Program.
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Locating Priority Areas
Staff detection, public reporting and water quality monitoring data (performed by Montreat
College and Warren Wilson College)will be used as methods for identifying areas that have a
higher likelihood of illicit discharges. Data compiled showing inspections conducted, spills
responded to, sewer leaks detected, notices of violation issued and service requests received
also identify priority areas for increased follow up activities by the Code Administrator. For
example, an area may be identified where several sewer leaks have been detected over a
short period of time. Increased follow up activities with the Metropolitan Sewerage District
would be assigned in this area to identifythe causes of these leaks and initiatethe measures
n ecessaryto prevent recurrence.
Procedures for Tracing the Source of an Illicit Discharge
Once a priority area is identified, standardized follow up activities will be performed to identify
and eliminate all illicit discharges. This will include a careful inspection of streams and other
surface waters for impacts from pollutants. All dry weatherflows will be identified and
observations will be made regarding the physical appearance of the stream. Field monitoring
equipment and laboratory samples will be used as necessary. Water quality problems will be
identified and traced upstream until sources are located.
Procedures for Removing the Source of the Illicit Discharge
Once the sou rce of a pollution problem is detected, the party responsible for the discharge will
be immediately identified and a verbal and/or written notice issued for violation of the
applicable section of the Stormwater Management Ordinance. Immediate discontinuation of
the discharge will be required by the notice and follow up activities will be conducted to ensure
compliance. All activitieswill be documented on a report form maintained bythe Code
Administrator.
Procedures for Evaluation of the Plan to Detect and Eliminate Illicit Discharges
Data compiled showing inspections conducted, spills responded to, sewer leaks detected,
notices of violation issued and service requests received will be used as measures to evaluate
the effectiveness of the above described plan to detect and eliminate illicit discharges. If the
plan is effective,the numberof pollution problems should be reduced over time. These
measures will be tracked and evaluated annually to determine the overall effectiveness of the
plan. If proven ineffective, the plan will be re-evaluated and changed as necessary.
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Incidental Non-Stormwater Discharges
The following incidental non-stormwater discharges associated with the following activities are
not considered as significant contributors of pollutants and will not be regulated by the
Stormwater Management Ordinance:
• Water line flushing;
• Landscape irrigation;
• Diverted stream flows;
• Rising ground waters;
• Uncontaminated ground water infiltration;
• Uncontaminated pumped ground water;
• Discharges from potable water sources;
• Foundation drains;
• Air conditioning condensation (commerciallresidential);
• Irrigation waters;
• Springs;
• Water from crawl space pumps;
• Footing drains;
Lawn watering;
• Individual residential carwashing and charitycarwashing;
• Flows from riparian habitats and wetlands;
• De -chlorinated swimming pool discharges;
• Street wash water;
• Flow from fire fighting activities; and
• Other non-stormwater discharges for which a valid NPDES discharge permit has
been approved and issued by the State of North Carolina, and provided that any
such discharges to the municipal separate storm sewer system shall be
authorized by the Town.
Non-Stormwater Discharges
All non-stormwater discharges not listed above are considered significant con tribu tors of
pollutants and are prohibited by the Stormwater Management Ordinance unless they are
permitted as an allowable discharge u n der a State issued permit.
Outreach
Montreat has developed and implemented a public outreach program to inform public
employees, institutions and the general public of illicit discharges and improperwaste disposal
and how they threaten the environment. Cross training of municipal employees also includes
techniques fordetecting illicit discharges. This outreach campaign includes instructions
regarding the proper method for reporting illegal discharges to Montreat. Regional public
service announcements as well as handouts and brochures are the primary outreach
mechanisms. Handouts and brochures have been developed are distributed during special
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NPDES RPE Stormwater Permit Application
events, when responding to citizen requests for service and in the Inspections Department.
This public outreach campaign is conducted by the Code Administrator and is included as a
componentof the Public Education and Outreach Program described in Section 7.1.
Employees in othermunicipal operations are informed of the threat to the environmentfrom
illicit discharges as well as the requirements of the Stormwater Management Ordinance
through the use of brochures and/or training. This training informs employees of the measures
n ecessary to preven t n egative impacts to su rface water resou rces.
Comprehensive Stormwater Management Plan (CSMP)
The Comprehensive Stormwater Management Plan (CSMP) mandates maintenance of the
outfall map and provides guidance in identifying locations with higher probability of evincing
illicit discharges. Town staff researched and proposed developing a stormwater utility that - as
part of the CSMP - will provide additional revenue to fund stormwater infrastructure
improvements; enable "green" retrofits to existing system features and developmentof more
structural SCM demonstration sites; and ensurefunding forincreased oversight, improved
monitoring techniques and maintenance of town wide stormwater infrastructure. The Town
Governing Board has chosen, to date, notto fund developmentof a utility. In addition to many
other fu nctions, the CSMP is the tool used to identify specific projects that will be implemented
through annual budgeting in the Capital Improvement Plan and pursuitof grant funding.
Contrasting future response effortswith the currentlevel of effective response to alleged illicit
dischargeswill provide clear performance indicatorsfor evaluating procedural and system
effectiven ess.
Evaluation
The overall success of the Illicit Discharge Detection and Elimination Program is being
measured through improvements in water quality conditions. The success of the individual
measurable goals established foreach of the SCMs associated with the program follows:
Complete Storm Sewer Maps: The initial mapping process was completed in 2005. The
measurable goal associated with this SCM is the completion of an effective GIS-based digital
map that clearly illustrates the locations of inlets, outlets and receiving streams with the Town.
As funding is made available, we plan to complete the digital mapping project before the next
permit renewal cycle.
Develop and Enforce a Stormwater Management Ordinance: The measurable goal associated
with this SCM was successfuIlyfulfilled in 2009with the development, adoption and successful
implementation of the Ordinance. Enforcement of this ordinance is ongoing.
Employee Cross -training: Each publicworks employee, the town administrator and code
administrator attended regional training on illicitdischarge detection and elimination as well as
good housekeeping practices. This training will continue to be required for new employees in
these departments.
Develop and Implement a Public Outreach Program: The completion of the regional public
service announcements, newsletterarticles, handouts, brochures and newspaperads was
initiated in 2005 and 2006. These ads contain information to heighten public awareness of
local water quality concerns and include instructions for property reporting illegal discharges to
the Town.
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Section 7.4 Construction Site Stormwater Runoff Control
SCM Summary Table for Construction Site Stormwater Runoff Control
`Me�suirab a Goals;
�'YR
six ,R
f
pZ f
YR'
Y- R y
°YR'
5
'Res onsible -
p .4w
w
Posifion _..
4
Enforcementof
Coordinate local
X
X
X
X
X
Code
County Erosion
complaints and building
Administrator
and Sediment
permits with the Buncombe
Control Program
County Erosion and
Sediment Control Program
staff.
The Town has adopted Buncombe County's Sedimentation and Erosion Control Ordinance
that regulates development projects of one acre or more, and coordinates with the countyon
permitting, inspections and enforcement (see Appendix C). Initial plan review by the Town
Inspections Department determines which projects will be coordinated with Buncombe County
for permitting, inspections and additional oversight.
Section 7.5 Post -Construction Storm Water Management in New Development and
Redevelopment
SCM Summary Table for Post -Construction Stormwater Management in New
Development and Redevelopment
SCM
NOW rafals G,.oals
YR
YR"
YR ,
YR
4
YR
,5
'Responsible
Posifiori
5
Enforce a Post
Enforce the model Post Construction
X
X
X
X
X
Code
— Construction
Stormwater Discharge Ordinance that
Administrator
Stormwater
meets the requirements contained at
Discharge
section 15A NCAC 21-1.0126(10), Post
Ordinance
Construction Stormwater Management.
Require deed restrictions and protective
X
X
X
X
X
Code
covenants to maintain the facilities and
Administrator
restrictions.
Enforce a 30 foot separation between
X
X
X
X
X
Code
built -upon areas and surface waters.
Administrator
Limit slope construction and encourage
X
X
X
X
X
Code
LID and conservation design.
Administrator
Encourage Green Infrastructure
X
X
X
X
X
Code
Practices
Administrator
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Stormwater Management Ordinance
The Town has adopted a local Stormwater Management Ordinance (see Appendix B) that
regulates development and redevelopment projects with as little as 5,000 SF disturbed area,
24% total lot area developed to include impervious cover, or the addition of 2,500 SF
impervious cover. This ordinance imposes more rigorous review and permitting requirements
than were enforced under Bu ncombe County's Stormwater Ordinance previously in effect.
The intentof our current ordinance is to regulate post -construction water quality and quantity
such that it mimics pre -construction values, and encourages the use of SCM's in the planning
phase so that the negative impacts to water quality are minimized to the greatest extent
feasible.
Operation and Maintenance Agreement
In General - Prior to the conveyance ortransfer of any lot or building site to be served by a
structural SCM, the applicantor ownerof the site must execute an operation and maintenance
agreement that is binding on all subsequent owners of the site, portions of the site, and lots or
parcels served by the structural SCM. Until the transference of all property, sites, or lots served
by the structural SCM, the original owneror applicantwill have primary responsibility for
carrying out the provisions of the maintenance agreement.
Performance Security - The Town may, at its discretion, require the submittal of a performance
secu rity or bon d with su rety, cash escrow, letter of credit or oth er acceptable legal
arrangement prior to issuance of a permit in order to en su re thatthe structu ral SCMs are (1)
installed by the permit holder as required by the approved stormwater man agementplan,
and/or (2) maintained by the owner as required by the operation and maintenance agreement.
This requirementmay be instituted in addition to and in conjunction with other performance
security or bond requirementsthe Town may require in conjunction with a subdivision or
development plan. The amou n t of a maintenance performance secu rity is determined based
on the type of SCM and a projected annual maintenance cost as recorded in the maintenance
agreement.
Deed Recordation and Indications on Plat- The applicable operations and maintenance
agreement, including butnotlimited to conservation easement, or dedication and acceptance
into public maintenance, pertaining to every structural SCM will be referenced on the final plat
an d be recorded with the Cou my Register of Deeds u pon fin al plat approval. If no su bdivision
plat is recorded for the site, then the operations and maintenance agreement, or conservation
easement, or dedication and acceptance into public maintenance, [whichever is applicable] will
be recorded with the County Register of Deeds so as to appear in the chain of title of all
su bsequent purchasers u ndergenerally accepted searching principles.
Records of Installation and Maintenance Activities -The ownerof each structural SCM is to
keep records of inspections, maintenance, and repairs for at least five (5) years from the date
of creation of the record and submitthe same upon reasonable requestto the Stormwater
Administrator. Every structural SCM installed must be made accessible for adequate
maintenance and repair in accordance with the maintenance agreement, including, but not
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limited to a maintenance easement. If a maintenance easement is provided then it will be
recorded and its terms will specify who may make use of the easement and for what purposes.
Site Plan Requirements and Review
All permitted projects require site plan review. The stormwater permit application is required to
describe in detail how post-developmentstormwater run-off will be controlled and managed,
the design of all stormwater facilities and practices, and how the proposed project will meet the
requirements of the ordinance. The following information is required as part of the submittal:
Existing Conditions / Proposed Site Plans - Existing conditions and proposed site layout sketch
plans,which illustrateata minimum: existing and proposed topography; perennial and
intermittent streams; mapping of predominant soils from soil surveys (when available);
boundaries of existing predominant vegetation and proposed limits of clearing and grading;
and location of existing and proposed roads, buildings, parking areas and oth er impervious
su rfaces.
Natu ral Resou rces Inventory - A written or graph is inventory of th e n atu ral resou rces at th a site
and surrounding area as it exists prior to the commencement of the project. This description
should include a discussion of soil conditions, forest cover, geologic features, topography,
wetlands, and native vegetative areas on the site, as well as the location and boundaries of
other natural feature protection and conservation areas such as lakes, ponds, floodplains,
stream buffers and other setbacks (e.g., drinking waterwell setbacks, septic setbacks, etc).
Particular attention should be paid to environmentally sensitive features that provide particular
opportunities or constraints for development.
Stormwater Management System Plan - A written or graph is concept plan of the proposed
post-developmentstormwater management system including: preliminary selection and
location of proposed structural stormwater controls; low impact design elements; location of
existing and proposed conveyance systems such as grass channels, swales, and storm drains;
flow paths; location of floodplain/floodway limits; relationship of site to upstream and
downstream properties and drainages; and preliminary location of proposed stream channel
modifications, such as bridge or culvertcrossings.
Additional targeted impacts to water quality include:
Fecal Coliform - The Town Building Inspectorcoordinates with the Buncombe County Health
Department to track scheduled maintenance and inspection ofthe few, privately -owned
existing on -site wastewater treatment facilities. Recently adopted town policy prohibits
installation of any new, privately -owned on-sitewaste treatment facilities and requires
connection to the public sanitary sewer system administered by the Metropolitan Sewerage
District of Buncombe County.
Trout (Tr) Waters and Other Streams - In addition to standards for stormwater handling set out
in the design manual, larger developmen t an d redevelopment projects that drain in whole or
part to class TR waters must design and implement the best stormwater practices that do not
result in a sustained increase in the receiving water temperatu re, while still meeting the other
requirements of the ordinance. Smaller qualified projects that are determined to create a
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potential negative impact to class TR waters due to design, type of improvement, or other
relevant factors, are also be required to comply with this standard. The Town has no
designated nutrient -sensitive waters receiving drainage/discharge that have been identified.
General requirements with the Ordinance limit built -upon areas from encroaching within thirty
(30) feet landward of all identified perennial and intermittent streams.
SCMs Related to Area -Based Requirements
Larger Development Projects - All stormwater management plans relating to subdivisions or
developmentor redevelopment plans on lots equal to or greater than one acre, or on lots less
than an acre with at least 10,000 square feet disturbed area, or which are part of a larger
common plan of developmen t or sale, including a subdivision, Planned Unit Development, or
other Special Use must be prepared by a qualified registered North Carolina professional
engineer, environmental scientistor landscape architect, and the consulting professional can
perform services only in their area of competence. The Stormwater Administrator will
determine if the consulting professional may verify that the design of all stormwater
managementfacilities and practices meets submittal requirements for complete applications,
and that the designs and plans are sufficient to comply with this ordinance.
For larger development projects, the designerof the stormwater management measures and
plans must certify, under seal, that the as -built stormwater measures, controls, and devices are
in compliance with the approved stormwater management plans and designs and with the
requirements of the ordinance. A final inspection and approval by the Stormwater
Administrator must occurbefore the release of any performance securities or a Certificate of
Occu pan cy is issued.
Smaller Projects - Stormwater management plans relating to development or qualifying
redevelopmenton lots less than 10,000 squarefeet disturbed area in size must meet the
minimum permit application requirements of Section 304. 1-3 of the Ordinance (see Appendix
B), and applicants must provide designs demonstrating adequate stormwater management
measures selected from a list of approved SCM's as follows:
• Diffuse or Directed Flow Designs
• Rain Gardens
• Backyard Wetland
• Stormwater Collection (Cistern)and Reuse Systems
• Vegetated Swales
• Impervious Removal
• Permeable Pavement*
*Due to the higherclaycontentand low permeability of many soils in our region , permeable
pavement's usefulness is limited to detention as a stormwater managementtool in Wester
North Carolina.
As -Built Plans and Final Approval - Upon completion of a project, and before a certificate of
occupancy is granted, the applicant must certify that the completed project is in accordance
with the approved stormwater management plans and designs, and submits actual "as built'
plans for all stormwater managementfacilities or practices after final construction is completed.
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The plans must show the final design specifications for all stormwater managementfacilities
and practices and the field location, size, depth, and planted vegetation of all measures,
controls, and devices, as installed.
Enforcement
Inspections and inspection programs by the Town may be conducted or established on any
reasonable basis, including but not limited to routine inspections; random inspections;
inspections based upon complaints orother notice of possible violations; and joint inspections
with other agencies inspecting under environmental or safety laws. Inspections may include,
but are not limited to, reviewing maintenance and repair records; sampling discharges, surface
water, groundwater, and material or water in SCMs; and evaluating the condition of SCMs. No
person may obstruct, hamper or interfere with the Stormwater Administrator while carrying out
his or her official duties.
Natural Resource and Open Space Protection
Several years ago, the Montreat Conference Center placed approximately 2,500 acres
surrounding the Town into a conservation easementthat will permanently protect this area
from future development. The easement will protect critical habitats that aid in protecting and
improving water quality by increasing infiltration and groundwater recharge, preventing erosion
and contamination of groundwater resources and protecting sources of drinking water. In the
1980's, the Conference Cen ter in conjunction with the Town agreed to preserve areas around
certain streams, parks and trails through the Greenspace Agreement. The conservation area
along with the designated Greenspace areas protects an estimated sixty percent (60%) of
developable property in Montreat.
In 2007, the Town adopted the Open Space Conservation Plan. The primary focus of the
Open Space Conservation Plan is to enhance the Town's abilityto protect lands with high
natural resource value. Specific goals of the plan are found in Part III.
Green Infrastructure Practices
"Green" Street Standards - As referenced earlier, the Town of Montreat has adopted guidelines
for integrated stormwater managementand structural SCMs in its Street Standards Ordinance
as an additional method of directing increased use of these measures in Town infrastructure.
Provisions are in place that allows reduced street travel way width when stormwater featu res
are incorporated such as pervious shoulder materials. Conservation Subdivision design and
requirements detailed in our Hillside Development Ordinance further directs future
developmentwith strong consideration given to pre -development evaluation of natural site
drainage and planning practices that minimize introduction of impervious cover and site
disturbance. The collective impact of these adopted codes is in keeping with guidance
outlined in the Comprehensive Plan for Montreat and Low Impact Development practices
en cou raged by th a Town.
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Section 7.6 Pollution Prevention/Good Housekeeping for Municipal Operations
The Town of Montreat will develop and implement an operation and maintenance program
that includes a training componentand has the ultimate goal of reducing pollutant runoff
from municipal operations. Training materials developed through the EPA, the State of
North Carolina orregionallywill be used to develop this training program.
SCM Summary Table for Pollution Prevention/Good Housekeeping for Municipal
Operations
#
SCM
B
Measurable Goals; .
a .
= ....._ ..-
YR
1
YR
�2` 1;
YR
YR-
-YR ::Responsible
Position .
6
Implement a Municipal
Develop and adopt a
X
X
X
X
X
Department
Operations
Mu n ici pal Operation s
Heads and
Stormwater Protection
Stormwater Protection
Town
Program that specifies
Program.
Administrator
Town operationsto
minimize stormwater
Train employees to prevent
X
X
X
X
X
Department
pollution.
and reduce stormwater
Heads
pollution.
Conduct inspections of
X
X
X
X
X
Pu blic Works
Municipal operations
Director
Cary outgood-
X
X
X
X
X
Department
housekeeping policies for
Heads
stormwater pollution
prevention and reduce
pollutant run-off, particularly
sediment, from municipal
sites.
Affected Operations
This pollution prevention/good housekeeping program affects all municipal operations
generally, and adds responsibilities to the specific departments that maintain municipal
vehicles, properties and streets including the Police Department, Water Department, Street
Department and Sanitation Department.
The Town of Montreat does not own or operate transportation or transit services, a wastewater
treatment plant, landfill, mining operation, an airport or marina. The Town of Montreat does not
currently possess any general or industrial NPDES Permits.
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NPDES RPE Stormwater Permit Application
Training
The Town of Montreat staff is trained in maintenance activities which will inform employees of
the actions necessary to reduce the discharge of pollutants from their facilities and protect
water quality. Additionally, the Town provides opportunities forcontinued training of staff as
training opportunities arise. The Code Administrator has received training provided by NC
State University in stormwater SCM design, inspection and maintenance as well as training in
certification as an LID professional. All publicworks employees have received regional
training for illicit discharge detection and good housekeeping practices through the Land -of -
Sky Regional Council.
Maintenance, Inspections and Vehicular Operations
The Town regularly maintains streets and other facilities within the MS4through regularly
scheduled maintenance as part of Montreat's Municipal Operations Stormwater Protection
program. In addition, the PublicWorks Director is responsible forinspecting each facility
annually which includes: assessment of facility operations and maintenance activities;
evaluation of waste disposal methods; evaluation of water quality conditions; review of spill
response and clean up procedures; evaluation of housekeeping practices; evaluation of
outdoor storage facilities; and completion of a written report documenting findings and listing
corrective actions taken to minimize pollution sources and protectwater qualityto the
maximum extent practicable.
The Town of Montreat's fleetconsists of emergency service (police) vehicles, maintenance
trucks, and heavy duty trucks. Most vehicle maintenance services are provided by local motor
vehicle service stations, mechanics and tire shops. The public works department does limited
minorrepairs and day to day maintenance on vehicles, butoil change, lubrication and
comprehensive maintenance services are provided through local vendors.
Waste Disposal
The Town implements procedures for appropriate disposal of waste removal from the MS4 and
maintains a contract with CWS, Inc. fortransfer of waste collected within the Buncombe
County Solid Waste Service.
Other Evaluations, Decision Making Process and Outreach
Through the Comprehensive Stormwater Management Plan, the Town's stormwater
infrastructure is being evaluated and areas of improvement being identified forfuture funding.
The decision process for this SCM was based on the requirements of the Phase II program,
the existing conditions in Montreat, and our best judgment on the most effective method to
achieve these goals.
Evaluation
The Town evaluates training, staff and policy performance through annual staff evaluations. In
addition the Town has pursued and will continue to pursue the evaluation measures listed in
each of the previous section tables for our Phase II Program. Other measures of success
include the following: Numberof employees trained; Numberof Inspections Performed;
Number of Corrective Actions Taken; and Numberof Complaints Received.
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