NCS000466_Hillsborough 2004 SWMP_20040501

Town �•
of
Town of Hillsborough
Comprehensive Storm Water Management Program Report
May 1, 2004

TABLE OF CONTENTS
1. STORM SEWER SYSTEM INFORMATION............................................................ 3
1.1. Population Served
1.2. Growth Rate
1.3. Jurisdictional and MS4 Service Areas
1.4. MS4 Conveyance System
1.5. Land Use Composition Estimates
1.6. Estimate Methodology
1.7. TMDL Identification
2. RECEIVING STREAMS.......................................................................................
3. EXISTING WATER QUALITY PROGRAMS............................................................
3.1. Local Programs
3.2. State Programs
4. PERMITTING INFORMATION............................................................................ 4
4.1. Responsible Party Contact List
4.2. Organizational Chart
4.3. Signing Official
4.4. Duly Authorized Representative
S. CO -PERMITTING INFORMATION...................................................................... 4
5.1. Co-Permittees
5.2. Legal Agreements
5.3. Responsible Parties
6. RELIANCE ON OTHER GOVERNMENT ENTITY ....................................................
6.1. Name of Entity
6.2. Measure Implemented
6.3. Contact Information
6.4. Legal Agreements
7. STORMWATER MANAGEMENT PROGRAM..........................................................
7.1. Public Education and Outreach on Storm Water Impacts
7.2. Public Involvement and Participation
7.3. Illicit Discharge Detection and Elimination
7.4. Construction Site Stormwater Runoff Control
7.5. Post -Construction Storm Water Management in New Development and Redevelopment
7.6, Pollution Prevention/Good Housekeeping for Municipal Operations
APPENDICES......................................................................................................... 24
A — Hillsborough Subdivision Regulation
B — Orange County Sedimentation and Erosion Control Ordinance
C — Section 4.8, Subdivision Regulation
D — Hillsborough Organizational Chart
E — Section 5.2, Subdivision Regulation
F—Section 4.7, Subdivision Regulation
G — Section 4.6.3, Subdivision Regulation
H — Public Hearing Notice
I — Section 5.27, Zoning Ordinance

1. Storm Sewer System Information
1.1. Population Served: 5,535 - Seasonal population fluctuations are negligible.
Basis of Population statistic: Estimated by State Planning Office, Demographics Unit for July 1, 2002.
Population estimates are made July 1 of each year.
1.2. Growth Rate: 2.78% - The population growth rate for the service area was calculated based on the
simple analysis of the relative change between the U.S. Census population in 1990 and 2000 stated as
a percent change.
1.3. Jurisdictional and MS4 Service Areas:
1.3.1 Town Limits: 5.6 SQ. mi.
1.3.2 ETJ: 5.1 so. mi.
1.4. MS4 Conveyance System:
Conveyance for the MS4 in the Town of Hillsborough is handled with a combination of systems. These
include simple sheet flow discharge, sheet flow from streets, sidewalks, parking lots, and other
impervious areas that are collected by curb and gutter, concrete piping, grassed lined swales, as well as
some rip -rap lined and other armored ditches. A combination of retention, detention, and dissipation
systems are used at outlets prior to entering receiving waters. A large majority of the curb and gutter,
concrete piping, and armored ditches are within an NCDOT right of way and are the responsibility of
the division maintenance office.
In an effort to minimize the disruption of storm water flow, maintenance activities consisting of periodic
inspection, repair, cleaning, vegetation control, and debris removal are performed by the Town staff
and NCDOT were applicable.
1.5. Land Use Composition Estimates:
Estimated percentage of iurisdictional area containing the following land use activities:
Residential: 26 %
Commercial: 14 %
Industrial: 4 %
Open Space: 56 %
1.6. Estimate Methodology: Estimated from the Orange County Land Use GIS database.
Area of parcels for each designated land use type were summed and calculated for relative percentage
of the planning jurisdictional area.
1.7. TMDL Identification: Hillsborough receiving streams are not designated TMDL
2. Receiving Streams
Receiving Stream
Stream Segment
Water Quality
Classification
Use Support Rating
Water Quality Issues
Eno River
27 - 2 - 3.5
Ws II
H W NSW, CA
Some development
Sevenmile Creek
27 - 2 - 6 - 1.5
WS II
H W NSW CA
Develo meet & Urban runoff
3. Existing Water Quality Programs
3.1. Local Programs:
3.1.1 The Town Subdivision Regulation was originally adopted July 20, 1988. The entire Ordinance is
included as Appendix A.

3.1.2 The Orange County Sedimentation and Erosion Control Program is authorized by legal
agreement to enforce, within Hillsborough Town limits and limits of the ETJ, the Orange County
Soil Erosion and Sedimentation Control Ordinance (Appendix B) effective December 7, 1983,
Orange County is delegated authority to implement the North Carolina Erosion and Sediment
Control Program in Orange County.
3.1.3 The Hillsborough Watershed Protection Program is addressed through the Subdivision
Regulation and includes all property located within the Lake Ben Johnston watershed. The
relevant portion of the regulation is Section 4.8 and is included as Appendix C.
3.1.4 The Town will sample and test for water quality issues in response to a call from a resident or
local business. Tests include temperature, dissolved oxygen, conductivity, ammonia, fecal
coliform, and any other tests deemed necessary on a case by case basis.
3.2. State Programs: The Town of Hillsborough relies upon State implementation of BMP's for State owned
roadways and associated drainage within the Town's jurisdiction.
4. Permitting Information
4.1. Responsible Party Contact List:
NPDES Phase II Measure
Contact
Position
Phone
Fax
email
Person
1. Public Education and
Vacant
Environmental Planner
919-732-1270
919-644-2390
Outreach
2. Public Participation and
Vacant
Environmental Planner
919-732-1270
419-644-2390
Involvement
3. Illicit Discharge Detection
Vacant
Environmental Planner
919-732.1270
919-644-2390
and Elimination
4. Construction Site Runoff
Reynolds
Orange County Erosion
919-245-2596
919-644-3002
[e-mail]
Control
Ivins
Control Su ervisor
5. Post -Construction Runoff
Vacant
Environmental Planner
919-732-1270
919-644.2390
Control
6. Pollution Prevention/Good
Vacant
Environmental Planner
919-732-1270
919-644-2390
HouseP in
1
4.2. Organizational Chart: Chart included as Appendix D.
4.3. Signing Official: Eric Peterson, Town Manager
Signing official's statement included in Section IV of this application.
4.4. Duly Authorized Representative: N/A
S. Co -Permitting Information
5.1. Co-Permittees: N/A
5.2. Legal Agreement(s): N/A
5.3. Responsible Parties: N/A
6. Reliance on other government entity to satisfy one or more permit obligations
Name of Entity: Orange Countv
Measure Implemented: Construction Site Storm Water Runoff Control
El

Contact Information for the Responsible Party:
• Contact Person: Reynolds Ivins. Erosion Control Supervisor
• Contact Address: Planning and Inspections Department
-306F Revere Road, P.O. Box 8181
Hillsborough, NC 27278
• Contact Phone Number: 919-245-2586
Legal Agreements: Yes, legal agreements are in place to establish the relationship and
responsibilities of both parties
Name of Entity: NC Department of Transportation
Measure Implemented: State -Owned Road Storm Water Runoff Control
Contact Information for the Responsible Party:
• Contact Person: Tommy Dyer, Division Maintenance Engineer
• Contact Address: District 7
1584 Yanceyville St.
Greensboro, NC 27253
• Contact Phone Number: 336-334-3637
Legal Agreements: Owner responsibility
7. Storm Water Management Program Plan
The Hillsborough Storm Water Management Program (SWMP) is designed to reduce the discharge of
pollutant laden storm water from the Municipal separate storm sewer system (MS4), to the maximum
extent practicable (MEP). This is an effort to protect water quality, and to satisfy the appropriate water
quality requirements of the Clean Water Act. This is best accomplished with the implementation of a plan
that includes both source control and delivery reduction measures.
Possible future benefits from an effective and comprehensive storm water management program are:
• Improved quality of surface water
• Improved quality of drinking water supplies
Land preservation from control and reduction of erosion
• Reduction of sanity sewer overflows due to storm water infiltration
Preserved and improved wildlife habitat
• Improved wetland and estuary habitats for fish, waterfowl, and other related animal life
• Decreased flooding
The Town of Hillsborough will develop and implement cost effective operation, maintenance, and training
programs using both non-structural and structural Best Management Practices (BMP's) to satisfy each of the
six minimum control measures. This plan will achieve the goals defined in the NPDES Phase II Regulations
while deriving the greatest benefit for the Town. The SWMP must be developed and fully implemented within
five years from the effective date of the issued NPDES storm water permit.
The following table summarizes the six required control measures as well as Hillsborough's strategy for
meeting or exceeding the requirements of the regulation.
NPDES PHASE II MEASURES
BASIC STRATEGY
1. Public Education and Outreach:
Hillsborough will develop its own basic education and
Requires that a program be in place to deliver
outreach programs and adopt elements of successful
information to the community offering ways to
programs that have already been implemented in the
eliminate polluted storm water.
region and the State.
2. Public Participation/Involvement:
The Town will hold a public hearing on the draft plan.
Requires the town to follow public notice
This will be a joint public hearing with the Town Board
requirements and recommends the involvement
and the Planning Board. This is an essential part of the
of citizen advisory committees.
ublic artici ation and involvement program.
3. Illicit Discharge Detection and Elimination:
Funds have been approved for the mapping of the storm

Requires the development and implementation of
water system. The Town will develop appropriate
a plan to detect and eliminate illicit discharges
enforcement measures.
including the mapping of the storm waters stem.
4. Construction Site Runoff Control:
Orange County currently enforces erosion and
Requires the development, implementation, and
sedimentation control on land disturbances greate95.2—
enforcement of an erosion and sedimentation
20,000-sq. ft. The Subdivision Regulation (Section
control program for land disturbances greater
Appendix E) requires developments to be constructed so
than 1 acre.
that they minimize damage from storm water runoff
upstream or downstream by generally minimizing the
disturbance to natural vegetation, minimizing the area of
impervious surface and maximizing the infiltration of
storm water into the groundwater system, and generally
requires the design and implementation of site -specific
storm water management plans. Section 1 of the
regulation describes the basic jurisdiction and means of
enforcement. (Appendix A
5. Post -Construction Runoff Control:
The Subdivision Regulation site design requirements also
Requires the development, implementation, and
address post -construction storm water runoff from new
enforcement of a program to address discharges
developments. Post -construction runoff is also controlled
of post -construction storm water runoff from new
by the requirements in Section 4.7 on Landscape and
development.
Buffer requirements (Appendix F). The town's storm
water management requirements also regulate
impervious surface and encourages the arrangement of
development to benefit water quality as provided for by
the town's open space requirements I Section 4.6.3
Appendix G .
6. Pollution Prevention/Good Housekeeping:
This plan addresses several good housekeeping
Requires development and implementation of a
components. Other good housekeeping components will
program with the goal of preventing or reducing
need to be formalized into standard operating
pollutant runoff from municipal operations.
procedures.
7.1 Public Education and Outreach on Storm Water Impacts
Requirements
You must implement a public education program to distribute educational materials to the community or
conduct equivalent outreach activities about the impacts of storm water discharges on water bodies.
Information must be provided on the steps that the public can take to reduce pollutants in storm water
runoff.
Guidance
You may use storm water educational materials provided by the state; EPA; environmental, public interest,
or trade organizations; or other MS4s. The public education program should inform individuals and
households about the steps they can take to reduce storm water pollution, such as ensuring proper septic
system maintenance, ensuring the proper use and disposal of landscape and garden chemicals including
fertilizers and pesticides, protecting and restoring riparian vegetation, and properly disposing of used motor
oil and household hazardous wastes. The EPA recommends that the program inform individuals and groups
how to become involved in local stream restoration activities, as well as activities that are coordinated by
youth service and conservation corps or other citizen groups. The EPA recommends that the public
education program be tailored, using a mix of locally appropriate strategies, to target specific audiences and
communities. Examples of strategies include distributing brochures or fact sheets, sponsoring speaking
engagements before community groups, providing public service announcements, implementing educational
programs targeted at school age children, and conducting community -based projects such as storm drain
stenciling and watershed cleanups. In addition, the EPA recommends that some of the materials or outreach
programs be directed toward targeted groups of commercial, industrial, and institutional entities likely to

have significant storm water impacts. For example, adequate programs would include providing information
to restaurants on the impact of grease clogging storm drains, and to garages on the impact of oil discharges.
You are encouraged to tailor the outreach program to address the viewpoints and concerns of all
communities, particularly minority and disadvantaged communities, as well as any special concerns relating
to children.
7.1.1 BMP SummaryTable
BMP's and Measurable Goals for Public Education and Outreach
BMP
Measurable Goals
YR
YR
YR
YR
YR
Responsible
1
2
3
4
5
Position/party
1
Distribute pollution
Distribute brochures through event displays as well
X
X
X
X
Environmental
prevention
as neighborhood and business associations. Direct
Planner
brochures, mailers,
mailers and utility bill inserts will also be utilized as
and inserts
necessary to reach all factions of defined audience.
These measures will include information on necessary
steps to reduce sources of pollution including proper
disposal of used oil, pet waste, and toxic materials,
and public reporting of illicit discharges.
2
Informational
Develop and maintain a storm water information
X
X
X
X
X-->
Environmental
Website and Hotline
page for the Town's internet website. Post the plan,
Planner
updates to the plan, and any other educational
information. Provide information on reporting storm
water issues through Hotline.
3
Promotion and
Provide information and training to local voluntary
X
X
X
X
X
Environmental
Participation in NC
watershed watch group formed to monitor streams in
Planner
Big Sweep
the watershed on an ongoing basis. Post data on the
Town Web site promoting similar activities within the
community as well as the resulting number of
participants and amount of wastes collected.
4
Quarterly Newsletter
Distribute quarterly newsletter through local
X
X
X
X-T
Environmental
newspaper and event displays. Each newsletter will
Planner
include an article that targets a specific storm water
issue and how citizens and businesses can reduce
their impacts.
4
Explore Various
Explore Media/Public Awareness resources —
X
X
X—>
Environmental
Media and Public
including cable TV, web sites, local newspapers,
Planner
Awareness
brochures, water and sewer bill inserts to
Resources
communicate program.
5
Schools Program
Develop age -specific educational information for use
X
X
X4
Environmental
in schools and for presentations to school age
Planner
children. Present information in appropriate forums.
6
Public Outreach
Develop and conduct an educational campaign to
X
X
X4
Environmental
Program
inform residents and businesses on the definition of
Planner
illicit discharges, reporting of illicit discharges, proper
waste disposal, possible sources of pollutants around
the home or business, actions they can take to
minimize these discharges, as well as the importance
of identifying and eliminating potential pollutant
sources. Promote proper disposal of waste oil,
antifreeze, household hazardous waste, integrated
pest management, include information on health
department regulations that apply to restaurants, and
include information on grease traps and waste
dis osal.
Storm Drain
The Town will inventory and evaluate storm drains
X
X
X
X
X
Environmental
Labeling
within the program area and develop guidelines and
Planner
Program
specifications for a Town -wide program to label
storm drains for public education.
[Note: " X4 "symbol for a BMP indicates that activity is ongoing or not complete within the 5-year timeframe of the plan.]
7

7.1.2 Target Audience
Residents and owners of commercial, industrial, and institutional entities within
the limits of the Town and the ET]. This covers all categories of land use within the Town's jurisdiction
and will allow the program to reach the vast majority of potential polluters with some form of
educational material within the 5-year timeframe of the plan. It is also the intention of the Town to
ensure that adequate material is developed for all factions of the residential population such as
minority and disadvantaged communities as well as children.
7.1.3 Target Pollutant Sources
Typical household and business generated pollutants including:
• Nutrients — Detergent, fertilizer, pet waste, and yard waste such as leaves, grass clippings, and pine
needles
The nutrients nitrogen and phosphorus not only cause landscape plants to grow, but an excessive
amount also causes algae to grow in our waterways. Algal blooms contribute to fish kills and block
sunlight for the underwater vegetation needed by fish and shellfish for food and cover. Pet waste in
our waterways, like human waste, contain many nutrients, other potentially polluting chemicals, and
can carry disease that can make water unusable for fishing, swimming, and drinking. Residents and
businesses would be educated on minimizing use of chemical lawn products, and proper methods of
disposal of these waste materials.
Hazardous chemicals — Automotive products such as motor oil and antifreeze; hazardous waste such
as household cleaners and paints; and pesticides (herbicides, insecticides, fungicides, rodenticides)
These materials are toxic, so they are harmful to humans and animals as well as the environment.
Toxins in our waterways can make water unusable for fishing, swimming, and drinking. Our streams
feed lakes used as drinking water reservoirs. Educational materials would describe proper methods of
disposal, and locations that accept these materials for disposal.
• Sediment — Soil, sand, silt, and clay
Sediment from disturbed, unvegetated, or unstable areas blocks sunlight from underwater vegetation,
smothers shellfish and fish habitat, and can potentially clogs fish gills,. It is the largest contributor of
storm water pollution by volume. The educational message would emphasize proper soil control
methods for homeowners and small contractors, and provide contact information to report problem
areas.
• Litter — Paper, plastic, metal, and other traditional solid wastes
Litter can clog the storm water system, contributing to street flooding, and often ends up floating or
washing ashore in streams and lakes. Plastic litter endangers aquatic animals that might eat it or
become entangled. Educational materials would emphasize preferred management techniques,
including litter and waste control, as well as promote involvement in clean up programs such as NC Big
Sweep and others.
7.1.4 Outreach Program
The critical mechanisms to deliver the designed message are intended to be readily available
brochures, printed media, presentations and exhibits during local events, and the internet. The Town
will consider participating with regional educational efforts, including the Clean Water Education
Program managed by the Triangle J Council of Governments. Additionally, the Town will provide
liaison, information and technical assistance to accomplish outreach through local groups including:
• Local interest groups
• Town Board and Planning Board.
• Homeowners Associations and neighborhood groups
• Civic and environmental groups
• Schools

7.1.5 Decision Process
The Storm Water Management Division will solicit input and voluntary cooperation from citizen groups
And school officials. The Storm Water Management Division will provide guidance on storm drain
stenciling. These processes and responsible individuals are detailed in the BMP table above.
7.1.6 Evaluation
Evaluation of this component will be accomplished by assessing achievements and progress
toward reaching each of the measurable goals listed in the BMP summary table. Progress will be
reported each year in the annual report to the State.
7.2 Public Involvement and Participation
Requirements
You must, at a minimum, comply with state and local public notice requirements when implementing a
public involvement/participation program.
Guidance
EPA recommends that the public be included in developing, implementing, and reviewing your storm water
management program, and that the public participation process should make efforts to reach out and
engage all economic and ethnic groups. Opportunities for members of the public to participate in program
development and implementation include serving as citizen representatives on a local storm water
management panel, attending public hearings, working as citizen volunteers to educate other individuals
about the program, assisting in program coordination with other pre-existing programs, or participating in
volunteer monitoring efforts.
7.2.1 BMP Summary Table
BMP's and Measurable Goals for Public Involvement and Participation
BMP
Measurable Goals
YR
YR
YR
YR
YR
Responsible
1
Public Hearing
Town Board and Planning Board held a joint public
1
X
2
3
4
5
Position Party
Environmental
hearing on March 29th. Number of citizens involved
Planner
will determine success of initial involvement effort.
2
Public Comment
Town received public comment for two weeks
X
Environmental
Period
following the public hearing. Number of citizens'
Planner
comments will determine success of initial
Participation effort.
3
NC Big Sweep
Promote and participate in NC Big Sweep and track
X
X
X
X
X
Environmental
activities within the community to include number of
Planner
participants, waste collected, and areas cleaned up.
Develop target areas to focus efforts concentrating
on creeks and large drainages.
4
Town Board and
Town Board and Planning Board will serve as a
X
X
X
X
X
Environmental
Planning Board
vehicle for review of input and implementation of
Planner
Input
program as well as future modifications as needed.
5
Storm Drain
The Town staff will inventory and evaluate potential
X
X
X
X
X
Public Works
Labeling Program
storm drain stenciling efforts and develop guidelines
Director/
and specifications for a Town -wide program to label
Environmental
storm drains. The Town work with volunteer groups
Planner
and schools to implement stenciling program to
encouracie public involvement.
(Note: X4 "symbol for a BMP indicates that activity is ongoing or not complete within the 5-year timeframe of the plan.]
0

7.2.2 Target Audience
The Town targeted all businesses types and all economic and ethnic groups of residents in publishing
a notice of the public hearing in one of the local newspapers, as well as on the Town's web page.
Residents, business owners, schools, the Town Board, and Volunteer Citizen Advisory
Boards are the target audience for the ongoing public participation efforts.
7.2.3 Participation Program
7.2.3.1 Public hearing
The Town Board and the Planning Board held a public hearing on March 29, 2004, prior to
submission of the final permit application. The goal of the public hearing was to reach out
and engage all economic and ethnic groups and provide opportunities for the public to
participate in program development and implementation. Application packet contains a copy
of the public hearing notice. (Appendix H)
7.2.3.2 Public Comment Period
The public hearing was followed by a two -week public comment period. Comments received
during the public hearing and public comment period have been evaluated and considered in
preparation of the final permit documents.
7.2.3.3 NC Big Sweep
The Town has participated in this program in the past with varying levels of involvement.
Hillsborough will continue to participate and increase promotion of the program with added
emphasis on streams and major drainages in town. Advance planning will identify target
areas and focus efforts where bigger problems exist.
7.2.3.4 Town Board and Planning Board Input
The Town Board and Planning Board will continue to give input into success of program
goals and possible future modifications as needed. Certain storm water related items have,
and will continue to be, a part of Town Board and Planning Board meetings, which are
advertised. These issues typically involve complaints - typically water quantity (flooding)
and water quality problems (mud washing onto owner's property; muddy streets; questions
about water quality). The public has the opportunity to bring these and other matters to the
attention of the commissions. These interactions will serve as an opportunity for the citizens
and citizen boards to address concerns and the elements of the program plan.
7.2.3.5 Storm Drain Labeling Program
The Town will work with citizen groups and with public school students to conduct storm
drain stenciling in the Town. The Storm Water Management Division will develop standards
and guidelines for a Town —wide storm drain stenciling and awareness program.
7.2.4 Decision Process
The Storm Water Management Division will solicit input and voluntary cooperation from citizen groups
and school officials, monitor progress and success, and coordinate activities and inputs from other
departments. These processes and responsible individuals are detailed in the BMP table above.
7.2.5 Evaluation
Evaluation of this component will be accomplished by the public interest shown in the permit
application development process, the above listed BMP's, and by regularly assessing achievements
and progress toward reaching each of the measurable goals listed in the summary table. Progress
will be reported each year in the annual report.
7.3 Illicit Discharge Detection and Elimination
IN

Requirements
Illegal discharges include the accidental and intentional disposal of chemicals, hazardous liquid, solid waste,
and debris into storm drains. In addition, illicit discharges may occur as a result of poorly
maintained or deteriorated sewer lines and from improperly functioning or maintained septic tanks and
leach fields. This category also includes the more complex problem of illegal connections to the storm
drains from homes and businesses. These illegal connections allow untreated wastewater from toilets,
sinks, floor drains, and other sources to be discharged into surface waters instead of into treatment
facilities.
(i) You must develop, implement, and enforce a program to detect and eliminate illicit discharges (as
defined at Sec. 122.26(b)(2)) into your small MS4.
(h) You must:
(A) Develop a storm sewer system map, showing the location of all outfalls and the names and location
of all waters of the United States that receive discharges from those outfalls;
(B) To the extent allowable under State or local law, effectively prohibit, through
ordinance, or other regulatory mechanism, non -storm water discharges into your storm sewer
system and implement appropriate enforcement procedures and actions;
(C) Develop and implement a plan to detect and address non -storm water discharges, including illegal
dumping, to your system; and
(D) Inform public employees, businesses, and the general public of hazards associated with illegal
discharges and improper disposal of waste.
(iii) You need address the following categories of non -storm water discharges or flows (i.e., illicit
discharges) only if you identify them as significant contributors of pollutants to your small MS4: water
line flushing, landscape irrigation, diverted stream flows, rising ground waters, uncontaminated ground
water infiltration (as defined at 40 CFR 35.2005(20)), uncontaminated pumped ground water,
discharges from potable water sources, foundation drains, air conditioning condensation, irrigation
water, springs, water from crawl space pumps, footing drains, lawn watering, individual residential or
non -regulated car washing, flows from riparian habitats and wetlands, dechlorinated swimming pool
discharges, and street wash water (discharges or flows from fire fighting activities are excluded from
the effective prohibition against non -storm water and need only be addressed where they are identified
as significant sources of pollutants to waters of the United States).
Guidance
EPA recommends that the plan to detect and address illicit discharges include the following four
components:
• Procedures for locating priority areas likely to have illicit discharges
• Procedures for tracing the source of an illicit discharge
• Procedures for removing the source of the discharge
• Procedures for program evaluation and assessment.
EPA recommends visually screening outfalls during dry weather and conducting field tests of selected
pollutants as part of the procedures for locating priority areas. Illicit discharge education actions may
include storm drain stenciling; programs to promote, publicize, and facilitate public reporting of illicit
connections or discharges, and distribution of outreach materials.
7.3.1 BMP SummaryTable
BMP's and Measurable Goals for Illicit Discharge Detection and Elimination
BMP
Measurable Goals
YR
3
YR
4
YR
5
Responsible
Position/Party1
Inventory storm
The town will develop and maintain an inventory of
X
X
X->
Engineer /
water system
the storm sewer system within the Town's
TYRYR
Environmental
jurisdiction.
Planner / Public
Works Director
2
Prepare storm
Develop and maintain a GIS-based map of all pipes,
X
X
X j
Engineer /
stem ma
outfalls,basins and other storm water treatment and
Environmental

BMP
Measurable Goals
YR
YR
YR
YR
YR
Responsible
1
2
3
4
5
Position/Party
conveyance devices, and receiving waters.
Planner / Public
3
Develop regulatory
The Town will seek legislative authority, and develop
X
X
X
Works Director
Attorney /
mechanisms to
an appropriate ordinance that prohibits illicit
Environmental
enforce illicit
discharges, specifies corrective measures and
Planner/ Public
discharge
penalties, and orovides for enforcement mechanism.
Works Director
4
Develop plan for
The Town will define illicit discharges that trigger
X
X
X4
Environmental
detection,
response action, and develop a plan to inspect,
Planner / Engineer
correction, and
detect and address illicit discharges (including illegal
/ Public Works
prevention of illicit
dumping) to the storm sewer system, and develop
Director / Deputy
discharges
procedure for correcting problems.
Fire Chief /
5
Evaluate local
The Town will evaluate the current level and location
X
X
X_>
Police Chief
Environmental
stream monitoring
of monitoring and determine if additional monitoring
Planner
efforts
needs are required to facilitate identifying and
TF
localizing problems. The Town will explore
cooperative solutions to identified gaps.
6
Explore funding
The Town will explore opportunities to acquire
X
X
X
X
X�
Environmental
funding to implement the illicit discharge detection,
Planner
correction and prevention plan.
7
Explore cooperative
The Town will explore cooperative arrangements with
X
X-->
Environmental
arrangements with
jurisdictions
other jurisdictions to implement the inspection and
Planner / Public
other
enforcement provisions.
Works Director
8
Begin implementing
The Town will initiate implementation of the illicit
X
X-->
Engineer / Code
detection program
discharge detection, correction, and prevention plan
Enforcement
at a level commensurate with available resources.
Supervisor / Public
Works Director/
Deputy Fire Chief /
Police Chief
9
Train employees
The Town will develop and implement a program to
X
X-)
Environmental
train Town employees on detecting illicit discharges
Planner / Public
and proper response.
Works Director /
Code Enforcement
Supervisor/ Deputy
Fire Chief / Police
Chief
10
Public Outreach
Develop and conduct an educational campaign to
X
X_"
Public Works
Program
inform residents and businesses on illicit discharges,
Director /
reporting illicit discharges through Hotline, improper
Environmental
waste disposal, and requirements of the ordinance.
Planner
11
Evaluate non -storm
Hillsborough will begin to develop a plan to evaluate
X
X-)
Environmental
water discharges to
sources and occurrences of non -storm water
Planner / Public
the storm water
discharges or flows and determine if they are
Works Director
system
significant contributors of pollutants to the system
and develop strate ies to manage,
[Note: " X4 "symbol for a BMP indicates that activity is ongoing or not complete within the 5-year Urneframe of the plan.]
7.3.2 Storm Sewer System Map
The Town of Hillsborough does not currently have a storm sewer system map completed for the
regulated municipal separate storm sewer system. The map compilation began 4/04 and will depict, at a
minimum: city streets, topography or drainage patterns, blue line streams and intermittent blue -
line streams (as shown on USGS 1:24,000 scale quadrangle maps) and outfalls. The program will
involve an inventory of all storm drainage facilities on town owned public rights -of way within the
town's corporate limits and ETJ which show up on the 1998 Orthophotographic Mapping for
Orange County. Mapping of areas not shown on the Orthophotos and areas for which as -built
information is available will not be mapped. These areas will be added using the as -built
information provided by the developers of the property. The mapping program will include
12

determination of the following:
• Horizontal and vertical location of storm drainage structures and open end culverts
• Sizes and types of the piping connecting the drainage structures
• Type and condition of storm drainage structures
• Visual inspection of each structure to detect illicit discharges or other irregularities
The horizontal location of the storm drainage facilities will be delineated by utilizing the Orange
County Orthophotographic Mapping and the ArcView GIS system. Field location of the facilities
and other information related to each structure are input into ArcView by a survey team.
Elevations of the tops and inverts of the storm drainage structures are then field surveyed using
available vertical control (i.e. NCGS monuments, OWASA manholes, other bench marks) and are
input into ArcView.
It should be noted that the data will not include structures or lines within DOT maintained rights -of -
way.
Each of the storm drainage structures will be inspected for discoloration, odor, and the presence of
liquids other than water or anything else within the structure that would indicate past or
intermittent illicit discharge. Public Works will provide inspection of these structures as resources
permit, and will respond to detection and reports of illicit discharges from the general public.
7.3.3 Regulatory Mechanism
Before the Town of Hillsborough can proceed with development of an effective illicit discharge
detection and elimination program, a number of policy decisions must be made. The Town
currently does not have the authority to enter private property for inspection to detect illicit
discharges without permission of the property owner. The Town will evaluate existing legal
authority and pursue necessary mechanisms to gain necessary rights of access to implement the
program.
7.3.4 Enforcement
In order for the Town of Hillsborough to regulate connections and discharges into its storm water
system, it will be necessary to review existing ordinances and possibly amend or create ordinances
that define the following:
• Discharges that are prohibited
• Discharges that are permissible
• Define exemptions
• Correction Requirements
• Develop means to enforce rules, levy/collect fines or penalties
7.3.5 Detection and Elimination
Successful detection and elimination programs have used a wide array of techniques to address the
problem of illicit discharge. Inspection and monitoring of the system involves dry weather flow
investigations to determine the presence of illicit connections, the establishment of priority sites that
need more extensive investigation, and a reporting system for the public to notify officials of
questionable activities. To address the detection of illicit discharges and illegal dumping, programs
that accomplish the following will be developed.
• Increase community awareness of storm water quality issues (Example: School programs, volunteer
groups, websites, TV ads, publications, hotline)
• Routine and systematic water quality monitoring (Water sampling)
• Physically inspecting the Town's right-of-ways to identify illicit discharges
• Policies for sanitary sewer connection and response to sewer overflows/spills
• Remediation of hazardous chemical spills
• Conducting storm water systems inspections
13

• Building floor drain inspections
The Town plans to use primarily in-house staff to monitor for illicit discharge while out in the
community on routine duties as the front line in identifying potential problems (fire protection, public
safety, zoning and inspections, streets, and sanitation crews). By training these staff to identify
potential problems and proper response protocol, the Town can efficiently use existing resources to
implement the basic detection protocol for this part of the program.
7.3.6 Non -Storm Water Discharges
The Town will address those categories of non -storm water discharges or flows that are determined
to be significant contributors of pollutants to the system, including water line flushing, landscape
irrigation, diverted stream flows, rising ground waters, uncontaminated ground water infiltration (as
defined at 40 CFR §35.2005(20)), uncontaminated pumped ground water, discharges from potable
water sources, foundation drains, air conditioning condensation, irrigation water, springs, water from
crawl space pumps, footing drains, lawn watering, individual residential and non -regulated car
washing, flows from riparian habitats and wetlands, dechlorinated swimming pool discharges, and
street wash water. Discharges or flows from fire fighting activities are excluded from the effective
prohibition against non -storm water and will be evaluate to determine what action is appropriate
where they are identified as significant sources of pollutants.
7.3.7 Allowed Non -Storm Water Discharges
The Town will also evaluate other occasional incidental non -storm water discharges and identify those
that will not be addressed as illicit discharges because of either the nature of the discharges or
conditions the Town establishes for allowing these discharges to the system. All such incidental
discharges will be documented.
7.3.8 Outreach
The Town of Hillsborough has limited staff resources, and out of necessity will have to rely heavily on
achieving compliance voluntarily by providing education and incentives. Raising community wide
awareness of storm water issues will assist the Town in its efforts to reduce pollutant run-off.
Informative outreach and training programs will be developed as elaborated in section 7.1 to train
and inform businesses, residents, and town personnel of the following:
• Unpermitted practices
• Proper avenues for incident response
• Proper disposal of waste
• How chemical or solvent run-off has detrimental effects on the environment
• Irresponsible storm water management and the effect on the environment
It is important to note that the Town has very little industrial or light industrial activity, and it is likely
that focusing on education in these sectors will be more important than implementing a formal
inspection program.
7.3.9 Decision Process
The Planning Department will coordinate with Engineering and Public Works staff to complete and
maintain the system map. The Planning Department will also coordinate with the Fire Department and
Public Works Department to develop the detection and elimination program and the employee training.
These processes and responsible individuals are detailed in the BMP table above.
7.3.10 Evaluation
This component will be accomplished by assessing achievements and progress toward reaching each
of the measurable goals listed in the summary table. Progress will be reported each year in the
annual report.
14

7.4 Construction -Site Storm water Runoff Control
Requirements
You must develop, implement, and enforce a program to reduce pollutants in any storm water runoff to your
small MS4 from construction activities that result in a land disturbance of greater than or equal to one acre.
Reduction of storm water discharges from construction activity disturbing less than one acre must be
included in your program if that construction activity is part of a larger common plan of development or sale
that would disturb one acre or more. If the NPDES permitting authority waives requirements for storm
water discharges associated with small construction activity in accordance with Sec. 122.26(b)(15)(i), you
are not required to develop, implement, and/or enforce a program to reduce pollutant discharges from such
sites. Your program must include the development and implementation of, at a minimum:
A. An ordinance or other regulatory mechanism to require erosion and sediment controls, as well as
sanctions to ensure compliance, to the extent allowable under State or local law;
B. Requirements for construction site operators to implement appropriate erosion and sediment
control Best management practices;
C. Requirements for 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 impacts to water quality;
D. Procedures for site plan review which incorporate consideration of potential water quality impacts;
E. Procedures for receipt and consideration of information submitted by the public, and
F. Procedures for site inspection and enforcement of control measures.
Guidance
Examples of sanctions to ensure compliance include non -monetary penalties, fines, bonding requirements,
and/or permit denials for non-compliance. EPA recommends that procedures for site plan review include the
review of individual pre -construction site plan to ensure consistency with local erosion and sedimentation
control requirements. Procedures for site inspections and enforcement of control measures could include
steps to identify priority sites for inspection and enforcement based on the nature of the construction
activity, topography, and the characteristics of soils and receiving water quality.
You are encouraged to provide appropriate educational and training measures for construction site
operators. You may wish to require a storm water pollution prevention plan for construction sites within
your jurisdiction that discharge into your system. See Sec. 122.44(s) (NPDES permitting authorities' option
to incorporate qualifying State and local erosion and sediment control programs into NPDES permits for
storm water discharges from construction sites). Also see Sec. 122.35(b) (The NPDES permitting authority
may recognize that another government entity, including the permitting authority, may be responsible for
implementing one or more of the minimum measures on your behalf).
7.4.1 BMP Summary Table
BMP's and Measurable Goals for Construction Site Storm water Runoff Control
BMP
Measurable Goals
YR
YR
YR
YR
YR
Responsible
1
2
3
4
5
Position/Party
1
County implements
County implements and enforces construction site
X
X
X
I X
X4
Orange County Soil
storm water runoff control.
and Erosion Control
2
State and Federal
DOT will comply with local requirements on roadway
X
X
X
X
X4
DOT Division
Projects
projects within the Town's planning jurisdiction. The
Maintenance Engineer
State or Federal Agency in charge of other
or Project Lead
development projects will comply with all local
Agency
requirements.
3
Review
Review the effectiveness of the County and DOT
X
X
X
Environmental
effectiveness of
program to identify gaps in coverage,
rX-)
Planner/ Engineer /
County and DOT
communication or other opportunities for
Public Works Director
15

BMP
Measurable Goals
YR
YR
YR
YR
YR
Responsible
1
2
3
4
5
Position/Party
program
improvement.
[Note. X� symbol for a BMP indicates that activity is ongoing or not complete within the 5-year timeframe of the plan.]
7.4.2 Regulatory Mechanism
The Orange County Erosion Control Officer is authorized by resolution of the Hillsborough
Town Board to enforce within the town the Orange County Soil Erosion and Sedimentation
Control Ordinance. Orange County implements and enforces construction site storm water
runoff control within the Town of Hillsborough's jurisdiction as stated in the following
jurisdictional clause within the County Ordinance.
NOTE: For purposes of this section, "land disturbing activity" means any use of the land by
any person in residential, industrial, educational, institutional or commercial development,
highway and road construction and maintenance that results in a change in the natural
cover or topography and that may cause or contribute to sedimentation. Sedimentation
occurs whenever solid particulate matter, mineral or organic, is transported by water, air,
gravity, or ice from the site of its origin.
Sec. 32-6.Jurisdiction and effect.
(a) Jurisdiction. This chapter shall apply within the county, including the municipalities of
Carrboro, Hillsborough, and the portion of Mebane within the county, but excluding the
municipal boundaries and planning extraterritorial limits of Chapel Hill.
(b) Effect.
(1) It shall be unlawful, within the jurisdiction of this chapter, to engage in land disturbing
activity, except as provided in this chapter, without first obtaining a permit as required by
this chapter and without complying with the conditions of the issuance of the permit.
The Town of Hillsborough Subdivision Regulation (Appendix A) requires compliance with all requirements
of the Orange County Erosion Control Officer before issuance of a permit for any regulated
developments and authorizes the County to enforce the County Ordinance within the Town as specified
in the Land Use Ordinance.
The Town Zoning Regulation (Section 5.27 — Appendix I) ensure that no zoning, special
use, or conditional use permit may be issued and final plat approval for subdivisions may
not be given with respect to any development that would cause land disturbing activity
subject to the jurisdiction of the Orange County Erosion Control Officer or the North
Carolina Sedimentation Control Commission unless such officer or agency has certified to
the town either that:
(1) Any permit required by such officer or agency has been issued or any erosion
control plan required by such officer or agency has been approved; or
(2) Such officer or agency has examined the preliminary plans for the development
and it reasonably appears that any required permit or erosion control plan can be
approved upon submission by the developer of more detailed construction or
design drawings. However, in this case, construction of the development may not
begin (and no building permits may be issued) until such officer or agency issues
any required permit or approves any required erosion control plan.
16

7.4.3 Plan Reviews
The County Erosion and Sediment Control Officer performs plan reviews according to the Ordinance.
(Appendix B)
7.4.4 Enforcement
The County Erosion and Sediment Control Officer enforces according to the Ordinance. The Town
reports problems, potential violations, and citizen complaints to the County Officer. (Appendix B)
7.4.5 Inspections
The County Erosion and Sediment Control Officer conducts inspections according to the Ordinance.
(Appendix B)
7.4.6 Public Information
The Town directs inquiries and complaints from the public to the County Erosion and Sediment Control
Officer.
7.4.7 Decision Process
The Planning Department coordinates with the County Erosion and Sediment Control Office on a regular
basis. All plans that meet the plan review threshold are submitted for approval to the County and
approval of permits depends on issuance of approval of the erosion and sediment control plan for the
project. These processes and responsible individuals are detailed in the BMP table above.
7.4.8 Evaluation
Evaluation of this component will be accomplished by an ongoing evaluation of the effectiveness of the
County's program and other agency projects. Noted deficiencies and/or enhancements will be reported
each year in the annual report.
7.5 Post -Construction Storm Water Management in New Development and Redevelopment
Requirements
You must develop, implement, and enforce a program to address storm water 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 discharge into your small MS4. Your
program must ensure that controls are in place that would prevent or minimize water quality impacts.
You must also:
(1) Develop and implement strategies that include a combination of structural and/or non-structural best
management practices (BMPs) appropriate for your community;
(2) Use an ordinance or other regulatory mechanism to address post -construction runoff from new
development and redevelopment projects to the extent allowable under State, Tribal or local law;
(3) Ensure adequate long-term operation and maintenance of BMPs.
Your post -construction storm water management program must meets the following requirements:
Low Density Projects. Projects shall be permitted as low density if the project meets the following:
l (I) No more than 2 dwelling units per acre or 24 percent built -upon area BUA for all
residential and non-residential development;
(II) Storm water runoff from the development shall be transported from the development
by vegetated conveyances to the maximum extent practicable:
17

(III) All BUA shall be at a minimum of 30 feet landward of all perennial and intermittent
surface waters. For the purpose of this Rule, a surface water shall be present if the
feature is approximately shown on either the most recent version of the soil survey
map prepared by the Natural Resources Conservation Service of the United States
Department of Agriculture or the most recent version of the 1:24,000 scale (7.5
minute) quadrangle topographic maps prepared by the United States Geologic Survey
(USGS). An exception to this requirement may be allowed when surface waters are not
present in accordance with the provisions of 15A NCAC 2B .0233 (3)(a); and
(IV) The permit shall require recorded deed restrictions and protective covenants to ensure
that development activities maintain the development consistent with the approved
project plans.
High Density Projects. Projects exceeding the low -density threshold (established above in low
density section) shall implement storm water control measures that:
(V) Control and treat the difference in storm water runoff volume leaving the project site
between the pre and post development conditions for the 1 year 24 hour storm.
Runoff volume drawdown time shall be a minimum of 24 hours, but not more than 120
hours;
(VI) All structural storm water treatment systems used to meet the requirements of the
program shall be designed to have an 85% average annual removal for Total
Suspended Solids:
(VII) General Engineering Design Criteria for all projects shall be in accordance with 15A
NCAC 2H .1008(c);
(VIII) All BUA shall be at a minimum of 30 feet landward of all perennial and intermittent
surface waters. For the purpose of this Rule, a surface water shall be present if the
feature is approximately shown on either the most recent version of the soil survey
map prepared by the Natural Resources Conservation Service of the United States
Department of Agriculture or the most recent version of the 1:24,000 scale (7.5
minute) quadrangle topographic maps prepared by the United States Geologic Survey
(USGS). An exception to this requirement may be allowed when surface waters are
not present in accordance with the provisions of 15A NCAC 2B .0233 (3)(a); and
(IX) The permit shall require recorded deed restrictions and protective covenants to ensure
that development activities maintain the development consistent with the approved
project plans;
Guidance
If water quality impacts are considered from the beginning stages of a project, new development and
potentially redevelopment provide more opportunities for water quality protection. EPA recommends that
the BMPs chosen be appropriate for the local community, minimize water quality impacts, and attempt to
maintain pre -development runoff conditions. In choosing appropriate BMPs, EPA encourages you to
participate in locally based watershed planning efforts that attempt to involve a diverse group of
stakeholders including interested citizens.
When developing a program that is consistent with this measure's intent, EPA recommends that you adopt a
planning process that identifies the municipality's program goals (e.g., minimize water quality impacts
resulting from post -construction runoff from new development and redevelopment), implementation
strategies (e.g., adopt a combination of structural and/or non-structural BMPs), operation and maintenance
policies and procedures, and enforcement procedures. In developing your program, you should consider
assessing existing ordinances, policies, programs, and studies that address storm water runoff quality. In
addition to assessing these existing documents and programs, you should provide opportunities to the public
to participate in the development of the program.
Non-structural BMPs are preventative actions that involve management and source controls such as: policies
and ordinances that provide requirements and standards to direct growth to identified areas, protect
sensitive areas such as wetlands and riparian areas, maintain and/or increase open space (including a
dedicated funding source for open space acquisition), provide buffers along sensitive water bodies, minimize
impervious surfaces, and minimize disturbance of soils and vegetation; policies or ordinances that encourage
18

infill development in higher density urban areas, and areas with existing infrastructure; education programs
for developers and the public about project designs that minimize water quality impacts; and measures such
as minimization of percent impervious area after development and minimization of directly connected
impervious areas. Structural BMPs include: storage practices such as wet ponds and extended -detention
outlet structures; filtration practices such as grassed swales, sand filters and filter strips; and infiltration
practices such as infiltration basins and infiltration trenches.
EPA recommends that you ensure the appropriate implementation of the structural BMPs by considering
some or all of the following: pre -construction review of BMP designs; inspections during construction to
verify BMPs are built as designed; post -construction inspection and maintenance of BMPs; and penalty
provisions for the noncompliance with design, construction or operation and maintenance. Storm water
technologies are constantly being improved, and EPA recommends that your requirements be responsive to
these changes, developments, or improvements in control technologies.
7.5.1 BMP Summary Table
BMP's and Measurable Goals for Post -Construction Storm Water Runoff Control
BMP
Measurable Goals
YR
YR
YR
YR
YR
Responsible
1
2
3
4
5
Position Party
1
Encourage
Communicate to developers and architects through
X
X
X
X-)
Environmental
innovative storm
the development review process that the Town is
Planner / Engineer /
water BMPs
interested in the development of innovative BMP
Public Works
designs.
Director
2
Sponsor
Review recent design developments and applications
X
X
X�
Environmental
Workshops for
in North Carolina and elsewhere. Identify potential
Planner / Engineer /
Local Developers
sponsors and professionals to conduct training for
Public Works
local designers.
Supervisor
Develop protocol
Develop a protocol and schedule for inspecting BMPs
X
X
X
X
Engineer /
for inspecting
for proper operation and maintenance, including
Environmental
BMPs
requirements for maintenance and inspection plans
Planner / Public
for all new projects and existing facilities.
Works Su ervisor
4
Implement BMP
Begin to implement inspection of storm water
X
-
Engineer / Zoning
inspection
management facilities in private developments as
Enforcement Officer
program
resources allow.
/ Public Works
SuDervisor
UIUM; A7 syinuui iur d omr muicetes that activity is ongoing or not complete within the 5-year timeframe of the plan.]
7.5.2 Non -Structural BMPs
The Subdivision Regulation site design requirements also address post -construction storm water runoff
from new developments. Post -construction runoff is also controlled by the requirements in Section 4.7
on Landscape and Buffer requirements (Appendix F). The town's storm water management
requirements also regulate impervious surface and encourages the arrangement of development to
benefit water quality as provided for by the open space requirements (Section 4.6.3 — Appendix G).
The town's storm water management requirements in the Subdivision Regulation goal is to regulate
New developments so as not to cause damage in terms of water quality or quantity. Appropriate
stream buffer and impervious surface restrictions are provided for areas in and outside of water supply
watersheds. The arrangement of development to benefit water quality is provided for by the town's
open space requirements, which seek to protect and recognize "natural constraints" including stream
buffers, slopes, and wetlands. The town also provides regulations for its low to medium density
districts that control the amount of development (density) with regard to the degree of natural and
other constraints.
The Town has begun, and will continue to, encourage developers to utilize non -conventional low
impact development approaches to storm water management that go beyond water quantity and
quality controls to include prevention, infiltration, and a water budget approach. An effort will be made
to facilitate a workshop to inform developers of low impact development design options. The intended
result will be a more localized, practical approach to include series of raingardens, bioretention and
19

infiltration units, swales, and other systems that mimic nature's processes and clean the water before it
is coveyed to a stream or to groundwater.
For example developers are encouraged to take into account the hydrological lay of the land, preserve
existing wetlands, grade the lots for storm water runoff into raingardens, and design storm water
management systems to maintain pre -development hydrology after post -development buildout, thereby
minimizing perturbation to the current ecological equlibrium of the local watershed. The town is also
evaluating and encouraging use of successful pervious pavement surface applications and other means
of reducing impervious surfaces.
7.5.3 Structural BMPs
Predominately, our current system utilizes a combination of conveyance systems. These range from
sheet flow from street, sidewalks and shoulders into curb/gutter, concrete piping, grassed lined swales,
rip rap or armored ditches with a combination of retention, detention and dissipation systems at their
outlets prior to entering receiving waters.
Maintenance activities consist of periodic inspection, repair, vegetation control, street sweeping, and
debris removal to minimize disruption of the drainage flow.
7.5.4 Regulatory Mechanism
The Town of Hillsborough will apply the current Subdivision Regulation and Zoning Ordinance to
address post -construction runoff from new development and redevelopment so as to modify it as
needed to address any additional issues identified in implementation of this plan.
7.5.5 Operation and Maintenance
In Hillsborough, as well as other Municipalities of equivalent size, the effort to construct BMPs has been
substantially stronger than the effort to engage active maintenance programs. This is mainly due to
budget constraints, lack of staffing, and limited knowledge of the BMP-specific maintenance needs.
Successful operation and maintenance of BMPs requires significant effort and planning. Several issues
remain to be resolved in identifying responsibilities and strategies for implementing an operations and
maintenance program.
The other primary issue is determining precisely who is responsible for maintaining privately owned
storm water systems and systems connected to a public system. Even more problematic will be the
issue of storm water from public systems entering a private system on private property. Also to be
defined are operations and maintenance programs that are required for all storm water facilities, both
public and private, which are discharging into a regulated storm water system. This will require
systems defined as "private" to develop operational and maintenance programs, mirroring the town
requirements, and would require verification by the town for compliance.
The Town will begin requiring operation and maintenance plans for storm water BMPs, including an
annual self -reporting protocol, as part of pre -construction requirements, and to be addressed in future
homeowner association documents.
7.5.6 Decision Process
The Planning Department will evaluate the post -construction requirements and make any necessary
revisions to the permitting program in the required time frame. The Planning Department will
coordinate with Engineering and Public Works staff to improve the performance of storm water systems
and to evaluate low impact development strategies for inclusion. The Planning Department will
coordinate with Engineering and Public Works staff to develop and implement an operations and
maintenance accountability program. Developers are responsible for preparing operations and
maintenance plans for any storm water system on private property and property owners/owners
associations will be responsible for implementing the operations and maintenance program and self -
reporting. These processes and responsible individuals are detailed in the BMP table above.
20

7.5.7 Evaluation
Evaluation of this component will be accomplished by assessing achievements and progress toward
reaching each of the measurable goals listed in the summary table. Progress will be reported each year
in the annual .report.
7.6 Pollution Prevention/Good Housekeeping for Municipal Operations
Requirements
You must develop and implement an operation and maintenance program that includes a training
component and has the ultimate goal of preventing or reducing pollutant runoff from municipal operations.
Using training materials that are available from EPA, your State, Tribe, or other organizations, your program
must include employee training to prevent and reduce storm water pollution from activities such as park and
open space maintenance, fleet and building maintenance, new construction and land disturbances, and
storm water system maintenance.
Guidance
EPA recommends that, at a minimum, you consider the following in developing your program: maintenance
activities, maintenance schedules, and long-term inspection procedures for structural and nonstructural
storm water controls to reduce floatables and other pollutants discharged from your separate storm sewers;
controls for reducing or eliminating the discharge of pollutants from streets, roads, highways, municipal
parking lots, maintenance and storage yards, fleet or maintenance shops with outdoor storage areas,
salt/sand storage locations and snow disposal areas operated by you, and waste transfer stations;
procedures for properly disposing of waste removed from the separate storm sewers and areas listed above
(such as dredge spoil, accumulated sediments, floatables, and other debris); and ways to ensure that new
flood management projects assess the impacts on water quality and examine existing projects for
incorporating additional water quality protection devices or practices. Operation and maintenance should be
an integral component of all storm water management programs. This measure is intended to improve the
efficiency of these programs and require new programs where necessary. Properly developed and
implemented operation and maintenance programs reduce the risk of water quality problems.
7.6.1 BMP Summary Table
BMP's and Measurable Goals for Pollution Prevention / Good Housekeeping
BMP
Measurable Goals
YR
YR
YR
YR
YR
Responsible
1
2
3
4
5
Position/Party
1
Evaluate Town
Develop a plan to audit all Town operations and
X
X
X
X
X
Fire Marshall /
operations.
facilities to identify practices and situations that
Public Works
pose potential releases.
Director /
Environmental
Planner
2
Corrective Action
Implement actions to correct identified potential
X
X
X
X
X4
Town Manager / All
releases or to eliminate pollution sources.
Town Departments
3
Employee Training
Develop and implement training program to
X
X
X
X4
Environmental
increase employee awareness across all
Planner / Public
departments of implications of actions, and provide
Works Director/ Fire
information to alert them to opportunities for
Marshall / Code
pollution source reduction and controls.
Enforcement Officer
/ Personnel Director
All De artments
4
Public Awareness
Provide information to users of public facilities on
X
X
X
X4
Public Works
efforts and measures implemented, instructions for
Director /
proper use of facilities, and penalties for failure to
Environmental
comply. Communicate to businesses, institutions,
Planner / Town
and residents the importance of identifying and
Board / Planning
eliminating pollutant sources. Promote proper
Board
21

BMP
Measurable Goals
YR
YR
YR
YR
YR
Responsible
disposal of waste oil, antifreeze, household
1
2
3
4
5
Position Pa rty
hazardous waste, and least toxic pest management
Promote and participate in NC Big Sweep program
with added emphasis to clean up of streams and
major drainage ditches.
[Note: " X4 "symbol for a BMP indicates that activity is ononinn nr nnr rmmnmta :.,�rti.., µ.e r _C____ _� ._
__ ..__ __...�._� I.— Irw. a. ucnan:a u: Lilt: pidn.f
7.6.2 Affected Operations
All Town operations are impacted by the operation and maintenance program discussed in this section,
specifically:
7.6.2.1. Town Hall maintenance
7.6.2.2. Public Works operations and maintenance and storage facilities
7.6.2.3. Fire Station and equipment maintenance
7.6.2.4. Parks and Recreation facilities and grounds maintenance
7.6.2.5. Grounds maintenance
7.6.2.6. Streets and drainage system maintenance
7.6.2.7. Town Parking Lots
7.6.3 Training
The Town will develop and implement targeted training for all departments to improve employee
awareness of the corrective measures that are identified for the various operations and facilities. The
planning department will coordinate this training with training of departments that will have a role in
illicit discharge detection and elimination. In addition, public education on the measures put in place
under this component will be incorporated into the public education program to inform public users of
Town facilities of what is expected as proper use of facilities.
7.6.4 Maintenance and Inspections
The Town has implemented several notable measures that prevent or reduce pollutants entering
receiving waters during storm events. These include:
• Integrated Pest Management Program (IPM) - The Town of Hillsborough has committed to
Developing and adopting an IPM policy and program as a comprehensive approach that gives
priority to prevention and management of pests including insects, weeds, and plant disease by the
least toxic method. The policy will reduce the environmental and health risks associated with pest
management. Reduced loading of toxins in storm water runoff is one of the direct benefits of this
program.
• Street Sweeping — The Town will work towards purchasing a vacuum sweeper truck and, when
purchased, will regularly sweep for removal of potential sediments and pollutants from street
surfaces in the downtown district and on some arterial roads. Residential roads will be
swept on a rotating schedule as staff resources allow. It is estimated that the rotation will
probably take a month, so that most residential streets will be cleaned monthly. A total of
approximately 30 miles of Town streets will be swept in this program.
• Basin Clean Out Program - currently on as needed basis with more attention given to on -going
problem locations. A more systematic and routine schedule for conducting periodic maintenance
will be possible upon completion of the storm system map, and inspection protocol. The Town's
new sweeper will be equipped with a "wander hose" attachment that allows removal of debris and
sediments from curb inlets and catch basins.
• Reduction of Road Salt Runoff - The majority of the time Town crews utilize a mixture of 2/3
sand to 1/3 salt with an occasional pure roadway salt application only when there is significant ice
accumulation anticipated. Applications are targeted to hills, stop, and intersection approaches and
locations that tend to stay frozen longer due to daytime shading rather than treatment of the full
width and length of paved street. There are no "Bare Pavement" routes designated at this time
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within the Town's Maintained Street system. In addition, the storage of the Town's sand/salt is
contained within concrete slab/filled concrete block perimeter walls and protected from run-off by a
roofed structure covering the entire storage area.
• Vehicle Wash Area - Public Works has a wastewater separator tank that is connected to a
sanitary sewer system. Periodically, the contents of tank are removed by a licensed and regulated
disposal company.
The following potential sources need to be evaluated and corrective measures taken:
• Leachate from composting activities
• Storage of solvents and chemicals
• Storage of salt and sand and other materials
• Storage of street sweepings
• Fuel Storage and fueling activities
• Vehicle and equipment storage and maintenance areas
7.6.5 Other Evaluations
Other corrective measures, maintenance activities, and schedules will be developed as part of
implementation of this plan to include controls for preventing release of pollutants from town
operations. Specific operational areas that will be evaluated might include:
• Streets and Infrastructure: Scheduling of maintenance activities and inspection procedures for
street sweeping, leaf collections, and solid waste collections;
• Vehicle/Equipment Storage Facilities/Town Parking lots: Identifying target areas where oils and
liquids drip from vehicles/equipment and are subject to being transported to surface waters by
storm water run-off,
• Daily House Keeping Activities: Identifying improper disposal of cleaning agents and rinse water
from wash down of floors, surfaces, and equipment;
• Park Facilities: Identifying improper disposal of cleaning agents and rinse water from wash down of
restrooms,
• Portable toilets: Securing toilets from being spilled and developing spill remediation protocol;
• Town Property Sewer Systems (remediation of spills. or overflows)
• Storm Water Conveyance Systems: Formalize protocol and schedule for cleaning swales, catch
basins, and pipe systems and proper disposal of waste from clean-up operations;
• Road Salt/Sand: Evaluate storage conditions and application protocol and rates;
• Vegetation Control: Evaluate current chemical or herbicide storage and applications (refer to IPM
program) and evaluate mowing or right-of-way maintenance schedules;
• Town Building Floor Drains: Identify any improperly routed drains, and improper employee use;
• Solid Waste Operations: Evaluate debris and liquids from waste collection equipment cleaning
operations;
• Composting Facilities: Evaluate leachate management;
• Fleet Maintenance Operations: Identify improper disposal, storage, or insufficient containment of
oil and other automotive/ equipment fluids and chemicals;
• Vehicle washing activities: Ensure all vehicles are washed only in appropriate facilities.
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( 7.6.6 Decision Process
The Environmental Planner will coordinate with Public Works and Fire Department staff to develop a
strategy for evaluating operations and to develop a targeted employee training program. Each
department within the Town will be responsible for implementing the evaluation and training with
oversight and assistance provided by the Public Works and Fire Departments. The Environmental
Planner will track implementation.
7.6.7 Evaluation
Evaluation of this component will be accomplished by assessing achievements and progress toward
reaching each of the measurable goals listed in the summary table. Progress will be reported each year
in the annual report.
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