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STORMWATER DIVISION CODING SHEET
MS4 PERMITS
PERMIT NO.
LS D6 2-9
DOC TYPE
❑FINAL PERMIT
❑ ANNUAL REPORT
O�PPLICATION
❑ COMPLIANCE
❑ OTHER
DOC DATE
3 f 0
YYYYMMDD
r- F _� 4
MAR 10 2003
Transmittal 1I
��� If enclosures are not received as noted below,WOO4 r
please call sender or Woolpert at 704.525.6284
Date: March 7, 2003
To: Darren England
Stormwater & General Permits Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
We are sending you
Re: NPDES Phase II Stormwater
City of Burlington, North Carolina
Order Number: 59800-04-123
Shipped Yia: UPS OYCrlllght
❑ Shop Drawings ❑ Samples ❑ Specifications ❑ Plans ❑ Change Order
® Other NPDES Stormwater Permit Applications & applicable fees - City of Burlington
Copies
Date
No.
Description
1
NPDES Stormwater Permit Application Form SWU-264
3
City of Burlington Stormwater Management Plan
Remarks:
Pleasc contact me with any questions about this submittal.
Signature: AL �- pll�b
,Ferri Reid
704.525.6284 Ext, 306
WOOLPERT LLP
8731 Red Oak Boulevard, Suite 101 • Charlotte, North Carolina 28217-3958
7VY.5L5 VLUY ° Cd% 04.525.8549 ' VYYVVY.VYVVIFCII.LUIII
OFFICE USE ONLY
Date Rec'd
631,,)o3
Fee Paid
'� -7 , 5. L.Z�
Permit Number
tjt5bWVZY
State of North Carolina
Department of Environment & Natural Resources
Division of Water Quality
NPDES STORMWATER PERMIT APPLICATION FORM
This application form is for use by public bodies seeking NPDES stormwater permit coverage for
Regulated Public Entities (RPE) pursuant to Title 15A North Carolina Administrative Code 2H.0126. A
complete application package includes this form and three copies of the narrative documentation required
in Section X of this form. This application form, completed in accordance with Instructions fir
completing NI'DE,S',S'mall M,S'4 ,5'tnrmwater Permit Application (SWU-270) and the accompanying
narrative documentation, completed in accordance with Instructions_lbr Preparing the Comprehensive
,Stormwater Management Program Report (SWU-268) are both required for the application package to be
considered a complete application submittal. Incomplete application submittal may be returned to the
applicant.
1. APPLICANT STATUS INFORMATION
a.
Name of Public Entity Seeking Permit
Coverage
City of Burlington
b.
Ownership Status (federal, state, or local)
Local
c.
Type of Public Entity (city, town, county,
prison, school, etc.)
City
d.
Federal Standard Industrial Classification
Code
SIC 91-97
e.
Count s
Alamance
f.
Jurisdictional Area (square miles)
22
g.
Population
Permanent
45,158
Seasonal if available
h.
Ten-year Growth Rate
1.37%
i.
Located on Indian Lands
No
IL RPE 1 MSR SYSTEM INFORMATION
a.
Storm Sewer Service Area (Square miles)
22
b.
River Basins
Cape Fear
C.
Number of Primary Receiving Streams
92
d.
Estimated perccnta>e of jurisdictional area containing the following four land use activities:
• Residential
53%
• Commercial
10%
• Industrial
12%
• Open Space
25%
Total =
100%
C.
Are there significant water quality issues
listed in the attached application report?
No
NPDES RPE Stormwater Permit Application
111. EXISTING LOCAL WATER QUALITY PROGRAMS
a. Local Nutrient Sensitive Waters Strategy
No
b. Local Water Supply Watershed Pro cram
Yes
C. Delegated Erosion and Sediment Control Program
Yes
d. CAMA Land Use Plan
No
IV. CO -PERMIT APPLICATION STATUS INFORMATION
(Complete this section only if co -permitting)
a. Do you intend to co -permit with a
permitted Phase I entity?
No
b. If so, provide the name and permit number of
that entity:
• Name of Phase l MS4
• NPDES Permit Number
C. Do you intend to co -permit with another
Phase II entity?
No
d. If so, provide the name(s) of the entity:
e. Have iegai agreements been fmaiized
between the co-permittees?
NIA
V. RELIANCE ON A'L:TT: Tv ' ONE OR t:iORE OF iOUR PERMIT
TATi01i:OTHLD ISi
OBLIGATION (If more than one, attach additional sheets)
a. Do you intend that another entity perform
one or more of your pennit. obli ations?
Yes
b. if yes, identify each entity and the element ey will be implementing
• Name of Entity
Alamance County Health Dept.
• Element they will implement
Fecal control program (septic tanks)
• Contact Person
Carl Carroll, Director of Environmental Health
• Contact Address
209 Graham Hopedale Rd., Burlington, NC 27216
• Contact Tele hone Number
336.570,6367
C. Are legal agreements in place to establish
responsibilities
No
V1. DELEGATION OF AUTHORITY (OPTIONAL)
The signing official may delegate permit implementation authority to an appropriate staff
member. This delegation must name a specific person and position and include documentation of
the delegation action through board action.
a. Name of person to which permit authority
has been delegated
b. Title/position of person above
C. Documentation of board action delegating permit authority to this person/position must be
provided in the attached application report.
6SWU-264-103102 Pane 2
NPDES RPE Stormwater Permit Application
VIL SIGNING OFFICIAL'S STATEMENT
Please see the application instructions to determine who has signatory authority for this permit
application. If authority for the NPDES stormwater permit has been appropriately delegated
through board action and documented in this permit application, the person/position listed in
Section VI above may sign the official statement below.
1 certi& 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 quali fled 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 rf my knowledge and helief,' true, accurate,
and complete. 1 am aware that there are significant penalties for sub- ' 'ng false in formation.
including the possibility offines and imprisonment for vowinojS tlOn N.
4iunatii rR
Name
Jos h P. arbo
Title
a or
Street Address
425 S. Lexington Ave.
PO Box
P.O. Box 1358
City
Burlington
State
NC
Zip
27216
Telephone
336.222.5022
Fax
336.513.5452
E-Mail
Jbarbour r ci.burlin on.nc,us
Vlll. MS4 CONTACT INFORMATION
Provide the following information for the person/position that will be responsible for day to day
implementation and oversight of the Stormwater program.
a.
Name of Contact Person
Gary Hicks
b.
Title
Public Works Director
C.
Street Address
d.
PO Box
P.O. Box 1358
C.
City
Burlington
f.
State
NC
91
Zip
27216
h.
Telephone Number
336.222.5005
i.
Fax Number
336.222.5004
j.
E-Mail Address
Gh1cks@ci.burIington.nc.us
6SWU-264-103102 Paae 3
NPDES RPE Stormwater Permit Application
IX. PERMITS AND CONSTUCTION APPROVALS
List permits or construction approvals received or applied for under the following programs.
Include contact name if different than the person listed in Item Vill. If further space is needed,
attach additional sheets.
a.
RCRA Hazardous Waste Management
Program
b,
UIC program under SDWA
c.
NPDES Wastewater Discharge Permit
East Burlington WWTP NPDES permit number
Number
NCO023868
West Burlington WWTP NPDES permit number
NCO023876
Wastewater from the potable treatment process at
the water treatment plant is covered by NPDES
permit number NC0083828.
d.
Prevention of Significant Deterioration
PSD Program
e.
Non Attainment Program
f.
National Emission Standards for
Hazardous Pollutants (NESHAPS)
reconstruction a proval
g.
Ocean dumping; permits under the Marine
Protection Research and Sanctuaries Act
h.
Dredge or fill permits under Section 404 of
CWA
X. NARRATIVE APPLICATION SUPPLEMENT: STORMWATER MANAGEMENT
PROGRAM REPORT
Attach three copies of a comprehensive report detailing the proposed Stormwater management
program for the five-year permit term. The report shall be formatted in accordance with the Table
of Contents shown below. The required narrative information for each section is provided in the
Instructions for Preparing the Comprehensive Stormwater Management Program Report (SWU-
268). The report must be assembled in the following order, bound with tabs identifying each
section by name, and include a Table of Contents with page numbers for each entry.
TABLE OF CONTENTS
1. STORM SEWER SYSTEM INFORMATION
L l 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
6SWU-264-103102 Paae 4
NPDES RPE Stormwater Permit Application
EXISTING WATER QUALITY PROGRAMS
3.1 Local Programs
3.2 State Programs
6SWU-264-103102 Paaa 5
NPDES RPE Stormwater Permit Application
4. PERMITTING INFORMATION
4.1 Responsible Party Contact List
4.2 Organizational Chart
4.3 Signing Official
4.4 Duly Authorized Representative
5. Co -Permitting Information (if applicable)
5.1 Co-Permittee
5.2 Legal Agreements
5.3 Responsible Parties
Reliance on Other Government Entity
6.1 Name of Entity
6.2 Measure Implemented
6.3 Contact Information
STORMWATER MANAGEMENT PROGRAM
T I Public Education and Outreach on Stormwater 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 Stormwater Management in New Development and Redevelopment
7.6 Pollution Prevention/Good Housekeeping for Municipal Operations
6SWU-264-103102 Paae 6
RESOLUTION FOR AUTHORIZATION TO SUBMIT NATIONAL POLLUTANT
DISCHARGE ELIMINATION SYSTEM PHASE II PERMIT APPLICATION
AND STORMWATER MANAGEMENT PLAN
WHEREAS, the United States Congress passed the Clean
Water Act in 1972 and amended said Act in 1987 to address
controls for pollution carried by stormwater; and,
WHEREAS, the Environmental Protection Agency (EPA) was
authorized to define and proscribe a program of measures to
improve the quality of water in our national and state
streams, rivers and water bodies under the National
Pollutant Discharge Elimination System (NPDES) and
promulgated Phase 11 rules on December 9, 1999, affecting
communities and institutions under 100,000 population; and,
WHEREAS, the State of North Carolina is delegated by EPA
to establish a regulatory program for NPDES Phase II and
has established rules and regulations as required; and,
WHEREAS, the City of Burlington has been notified and is
legally designated to comply with the NPDES Phase 11
regulations as established by EPA and the state requiring
the submittal of a permit application and stormwater
management plan; and,
WHEREAS, the regulations require designation of the
legally responsible party and authorization for submittal
of the application and stormwater management plan; and,
WHEREAS, the City of Burlington supports the goals and
objectives of the regulatory program to provide a safe and
healthy environment for all its citizens.
NOW, THEREFORE, BE IT RESOLVED by the City Council of
the City of Burlington, North Carolina, that:
C r..-.�i o 1 T1.� Mo..r.r r�.f 1-1-,0 (�`i ter •�f Aii rl i n.-rt :-.n hi..-+-h
.JGUL. J-Vll 1 1111.. 1'1 [.l ,/V1 Vl l..11V t.1 Ly - 1JL --Ly LJ- -V -I IL
Carolina, Joseph P. Barbour, shall sign and submit on behalf
of the City of Burlington no later than March 10, 2003, the
necessary documentation for compliance with the NPDES Phase
LL program requLr.elilelll.J C1 eJl.G1ULL7iICU uy l.i1C at.a4c.
Section 2. The Mayor shall carry out all necessary
strategies and requirements as set forth in the stormwater
management plan developed and submitted as required by the
CERTIFIED COP.M
U CITY �I RN
r,iTv r
GTON "
ti r
NPDES Phase II regulations to ensure compliance on behalf of
the City of Burlington.
'Section 3. That this resolution shall take effect upon
passage.
Adopted this 4�' day of March, 2003.
CERTIFIED COPY,
CITY CLERK
CITY OF BURLINGTON
City of Burlington, North Carolina
Y
��li la.t`•'`3�
NPDES Phase II Stormwater Management Plan
City of Burlington
March 10, 2003
1.0 -STORM SEWER SYSTEM INFORMATION
1
1.1 Population Served
A,.,.orA,'ng to "nnn Ce�sus d.�l.. the r.a.-.Y�..nent....p population of'the O.'t.r of R..l:..ntnn is AA 011 Tharp is
lIL.NVt UL w cMvv �n..up u� u L un. Y�.�uiu u...�n YvN u�u LL vL L L � Ley vL yua I—E. u w __,1- , ...... ....�
no seasonal population.
' 1.2 Growth Rate
I
According to census information from 1990 and 2000, the annual growth rate for the City of Burlington is
1.37%.
1.3 Jurisdictional and MS4 Service Areas
The jurisdictional and MS4 service area of City of Burlington is 22 square miles. The ETJ area is 18.4
square miles, but the only legal authority that the City has within this area is the enforcement of the Soil
Erosion and Sedimentation Control Ordinance, and the City's Zoning and Subdivision Regulations.
1.4 MS4 Conveyance System
Like many cities of its size, the City of Burlington does not have any records of its storm drainage
conveyance system. It is assumed that most of the infrastructure is aging and in poor condition. The
downtown area of the City contains the majority of the culvert and pipe systems and catch basins.
Outside of the downtown area in the more rural areas of the City, the conveyance system consists mostly
of channels and ditches that run through backyards and feed into larger streams.
The City does not currently have a formal program to clean storm sewer inlet structures or pipes. The
portion of the conveyance system that is maintained is within the City's right-of-way. Currently, the
infrastructure is maintained by the City's Street Department as problems are reported by residents or
noted in the field by City personnel. Typical maintenance includes driveway culvert installation and clean
out, ditch maintenance, catch basin repairs and clean out, and headwall maintenance.
I 1Z I nnA I Ian Pnrrsw�n�i�inn Cc+�irr��fn�
l.N "U'"A V.71W VV11lr.IV7l�iVll l�r7411lIGlLGJ
�6s�
,Land<User ategor 4 _
,pan
:t f , �yar F�-p'„7J'�At v-..r .�r ;.r,. t?a"C yk h" 4 ,
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;3.�F h. l t r ,� yel '�.:.T
13.I y �' Ji!}�,�'i 1�.,,ss . FX W 'IVF
RaJ4:r�a?',r)4ii .rt` .;!}..: �. i�4/•.:.(i,'4 ��1'?1r,.
� � Yercenta c p�� �Y ;,
�<_ �, °'; _,rt, "'2
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.,.: Xv:.6+'r .•./11%kk � .� ,. ��, kr� �' ��rE�!`.^ ;-_`+�.'� 11
Residential
11.66
53%
Industrial
2.64
12%
Commercial
2.2
10%
Open Space
5.5
25%
TOTAL
22
lon.
City of Burlington, Noah Carolina
March 200.3 5tormwater Management FNlan
1.6 Estimate Methodology
The estimates were generated using percentages from the City's Land Use Composition Plan. It was
determined to use these percentages because the City's zoning does not recognize open space, which is
one of the required categories. In addition, zoning is not always a good indicator of actual land use.
1.7 TMDL Identification
According to the TMDL (Total Maximum Daily Load) information located at
http:Uh2o,enr.state.nc.us/tmdl/approved TMDLS.htm the City of Burlington does not discharge into any
body of water or receiving stream that currently has a TMDL allocation.
City of Burlington, North Carolina
March 2003 Sformwater Management Plan 2
1
1
1
1
1
1
1
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1
1
1
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2.0 RECEIVING STREAMS
Appendix A contains the streams in the Cape Fear River Basin that receive discharges from the City of
Burlington.
March 2003
City of Burlington, North Carolina
5tormwaier Management clan
3
I
3.0 EXISTING WATER QUALITY PROGRAMS
3.1 Local Programs
The City of Burlington is designated by the North Carolina Department of Natural Resources to
implement the Sediment and Erosion Control program within the City limits and the ETJ area. All land -
disturbing activities involving an area greater than one acre are required by law in the state of North
Carolina to operate under an approved erosion control plan. This plan must be obtained before work
begins l}i1 a site. t-uuioUg[i tracts ti:oilta[riirrg rcss irea[i one acre uv riot rcgi.iirc pcliiiiis, nucquntc. 11ILaSU1l..S
to prevent erosion and contain sediment on site are still required. The City of Burlington Engineering
Department, as the local enforcement agent for the control of land disturbing activities for the state of
North Carolina, administers an erosion control program within the City limits and extraterritorial
jurisdictional area. This program operates under the direction of the Land Quality Section of NCDENR,
which enforces the requirements of the Sedimentation Pollution Control Act of 1973 on a statewide basis.
The City also implements Watershed Supply Watershed Protection Regulations within the City limits and
the ETJ. These regulations are in place to protect the watershed areas and water supply lakes for the City
and to provide for a safe and potable water supply for present and future generations. The regulations
' include density limits, buffer regulations, site plan requirements, and penalties for violations.
3.2 State Programs
IThere are no state water quality programs implemented in the City of Burlington.
1
1
I
1
City of Nirlinntnn Nnrth r.nrnlinn
March 2003 5lormwater Management Plan
1
1
4.0 PERMITTING INFORMATION
4.1 Responsible Party Contact List
���; .Measurable Goal ; {,� �y5 .c„ MG�y 1y ty„ r �:•
1 .i ] - A k
y � y = Y�I ;i,x,-.:,,•. ♦>
'
A
i�d r 4a a%r,:r `9�' v �j� Y" 7.11 `.."I" ��'S7:z i?
r-rrx�.. .a..it, 7 ,� .i{,. M1a.+ arv.rk.
'o;? T�1�` R-N'T iF �
t '. i � 1" -.' C= � ''� P r a, 3 ;,�g s I,t `fir i y d `.u. ,,ri � �'
reW
4. r�ie., k...S-.a., +w.t�.. R...,.?�•.v.k'4+.r� �•�G;..;R
Minimum Measure 1.
• Develop educational materials
Gary L. Hicks, Public Works Director
• Storm water web site
P.O. Box 1358
• Educational presentations
Burlington, NC 27216
• Government access channel show
336.222,5009
• City Works newsletter
ghicks@ci.burlington.nc.us
• Business outreach program
Minimum Measure 2:
• Open meetings law
Gary L. Hicks, Public Works Director
• Big Sweep
P.O. Box 1358
• Household hazardous wastes
Burlington, NC 27216
+ Volunteer groups
zzr, ��� snnn
• Storm drain stenciling
ci.burlington.nc.us
ghicks@ci.burlington.nc.us
Minimum Measure 3:
• Storm sewer system map
Gary L. I -licks, Public Works Director
• Illicit discharge ordinance
P.O. Box 1358
• Illicit discharge detection and elimination
Burlington, NC 27216
• Public education
336.222.5009
hicks ci.burlin ton.nc.us
Minimum Measure 4:
NIA — City is already complying, no further
Jim Lauritsen, City Engineer
action needed
P.O. Box 1358
Burlington, NC 27216
336.222,5050
jlauritsen@ci.burlington.nc.us
Minimum Measure 5:
• Post -Construction ordinance
Jim Lauritsen, City Engineer
• Fecal coliform control
P.O. Box 1358
• Non-structural BlviPs
Burlington, NC 27216
• Structural BM.Ps
336.222.5050
• Operations and maintenance
jauritsen@ci.burlington.ne.us
Minimum Measure 6:
• Training
Gary L. Hicks, Public Works Director
• Vehicular operations
P.O- Box 1358
• Waste disposal
Burlington, NC 27216
• City facilities and properties
336.222.5009
• Storm drainage infrastructure maintenance
ghicks@ci.burlington.nc.us
• Ordinances
City of Burlington, North Carolina
March 2003 Stormwater Management Plan 5
4.2 Organizational Chart
The organizational chart for the City of Burlington is located in Appendix B.
4.3 Signing Official
The signing official for the City of Burlington is Joseph P. Barbour, Mayor. Contact information for Mr.
Barbour can be found in the permit application form.
March 2003
City of Burlington, North Carolina
Stormwater Management Plan
6
5.0 CO -PERMITTING INFORMATION
The City of Burlington will be submitting these permit requirements individually, therefore this section is
not applicable.
March 2003
Citv of Burlington. North Carolina
Stormwater Management Plan
7
I
6.0 RELIANCE ON OTHER GOVERNMENT ENTITY
The City of Burlington will continue to rely on the Alamance County Health Department, Environmental
Control Division, to regulate new and existing septic tanks within the City. All other permit -related tasks
will be performed by the City of Burlington.
I
1
I
1
■ City of Burlington, North Carolina
March 2003 Stormwater Management Plan 8
1
7.0 STORMWATER MANAGEMENT PROGRAM
The National Pollutant stem e Elimination Discharge Y (NPDES) Sprogram was established as the
P �
fundamental regulatory mechanism of the CWA. The NPDES program requires that a direct discharger of
' a pollutant into waters of the United States must obtain an NPDES permit. Initially, the permitting effort
was focused on municipal and industrial wastewater facilities. Although these discharges were controlled,
many impaired waterbodies remain impaired.
Subsequent studies have determined that diffuse (non -point) sources, e.g., storm water runoff from urban
and agricultural areas, construction sites, land disposal areas, and mining activities, are presently the
leading contributors to water quality impairment. Although storm water originates from various diffuse
sources, this runoff is frequently discharged through separate storm sewers or other conveyances.
Therefore, the CWA was amended in 1987 to include Section 402(p), which required the United States
. Environmental Protection Agency (EPA) to develop a comprehensive phased program to regulate storm
water discharges under the NPDES program. The NPDES Phase I rule, which was issued in November
' 1990, addressed storm water discharges from medium to large municipal separate storm sewer systems
(MS4s), which were communities serving a population of at least 100,000 people, as well as storm water
-7'-_1_____.. C .,. .7....E..:..1 �:..: �.., Tl.., 1:,-. ] 1 d 1H r�tn cnma �nvn citr �u vtivn
utscharges liuiu indusuial ai cavity. L11- _J.ng aiSo piaeeu permitting ie�{::...,...,. . �. .,....
' aCtlVltles.
r
The NPDES Phase II rule, which was promulgated in December 1999, addressed small municipal
separate storm sewer systPmc (MS4sl serving a nopulation of less than 100.000 people in urbanized areas.
Per 2000 Census data, the estimated population of the City of Burlington is approximately 45,000 and is
one of the communities in the state of North Carolina automatically designated into the NPDES Phase II
program. In the state of North Carolina, EPA has delegated the North Carolina Department of the
' Environment and Natural Resources (NCDENR) as the state permitting authority. The City of Burlington
must obtain permit coverage from NCDENR by March 10, 2003.
The City of Burlington, which is an owner/operator of a small MS4, will be required to reduce the
discharge of pollutants to waters of the State and the United States to the "maximum extent practicable"
to protect water quality. At a minimum, the City will be required to implement a Storm Water
' Management Program that must address the following issues:
• Specify Best Management Practices (BMPs) for six minimum control measures and implement them
to the "maximum extent practicable",
t• Identify measurable goals for these control measures,
• Develop an implementation schedule for these control measures or frequency of activities, and
• Define the responsible entity to implement these control measures.
In order to meet the above requirements, the first step is to identify activities related to storm water that
the City is currently doing. Representatives of Woolpert conducted interviews with various relevant
' members of the City staff. Staff members were chosen that deal directly and indirectly with storm water.
Staff members whose position or department could.play a major role in helping to meet permitting
requirements were also consulted. Representatives from the following areas or departments were
consulted: Public Works, Utilities, Engineering, Parks and Recreation, Planning, Public Information,
Finance, and GIS. Phone interviews were conducted with representatives who were suspected to
potentially have minor dealings with storm water issues, such as the Public Information Officer. Using
' information from these interviews and from numerous resources provided by these individuals, the
following narrative was developed and includes: a description of the six minimum control measures, the
March 2003 City of Burlington
5tormwater Management Plan 9
performance requirements for each, the current relevant City activities and their respective deficiencies,
and an action plan to address those deficiencies for each minimum measure.
The State requires that the City of Burlington implement the six minimum measures throughout the City's
' jurisdictional area, including the ETJ (extra -territorial jurisdictional) area. This poses many difficulties,
mainly in how the City may obtain authority to tax an area that does not have representation and is not
served by City water or sewer services. Since the City does not currently have legal authority over the
ETJ area they will be unable to implement the Phase II program in this area, with the exception being the
' Soil Erosion and Sediment Control ordinance and the City Zoning and Subdivision Ordinances, which are
implemented throughout the ETJ area. However, the City will make available public education materials
to residents living in these areas.
' 7.1 Public Education and Outreach on Stormwater Impacts
mr- --- •_ — _—a .. _. ll,... a:.....,�,.«.........,. t,,.. ., 1, e..;-.., ...fl.
. 1lrG &fZy iV iitlptettecttuttg attu armua�,rttr, urr erreerrve , ur water grog, at... vl.r,ura WJtta wt t t...�.., LY
involvement. With this, greater support is typically achieved as the public gains an understanding of the
reasons why it is necessary and important. Public support is also beneficial when municipalities attempt
' to institute new funding initiatives or when recruiting volunteers. In addition, greater compliance with
nrov-r,am reninrementc is experienced as the awareness of personal responsibilities and their impact
toward protecting and maintaining the quality of area waters is achieved.
To satisfy this control measure, the City of Burlington must implement a public education program to
educate the public regarding the importance of proper storm water management. At a minimum, the City
must perform the following tasks:
• Implement a public education program to distribute educational materials to the community or
' conduct equivalent outreach activities to communicate the impacts of storm water discharges on local
water bodies. In addition, this program must address steps that can be taken to reduce storm water
pollution; and
• Determine appropriate best management practices and measurable goals toward developing a public
' education and outreach program.
Examples of public education and outreach measures are abundant, as shown below. These materials,
which should be tailored toward relevant local situations and issues, will involve a variety of strategies to
ensure maximum coverage.
I
7.1.1 BMP Summary Table
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Produce and broadcast a public
X
Gary L. Hicks /
Announcement
service announcement on the
Public Works Dir.
government access channel
and Jennifer
concerning water quality in the City
Smith / Public
of Burlington and what citizens can
Information
do to improve water quality
Officer
2
1 Educational efforts
Begin water quality education efforts
g q tY
X
Gary L. Hicks /
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in schools
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Public Works Dir._I
■ March 2003 City of Burlington
Stormwater Management Plan 10
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Generate and
Generate and distribute general
X
Gary L. Hicks 1
distribute
educational brochures explaining the
Public Works Dir.
educational
environmental impacts of stormwater
brochures
run-off as well as simple ways
residents can help reduce pollution in
their community.
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Public Works Dir.
program characteristics
5
City Works
Create one water quality -related
X
Jennifer Smith /
Newsletter
article to include in the City Works
Public
newsletter
Information
Officer
6
Stormwater Hotline
Implement a stormwater hotline that
X
Gary L. Hicks 1
residents can call with water quality
Public Works Dir.
and quantity concerns
7
Business Outreach
Generate and distribute target
X
Gary L. Hicks /
Program
educational materials to inform
Public Works Dir.
businesses on illicit discharges,
f
reporting and proper waste disposal
1
practices.
1 7.1.2 Target Audience
1
' The City of Burlington aspires to reach a diverse population with its public education campaign. Target
groups include residential property owners, commercial and industrial business owners, school -aged
children and community leaders. These groups are being targeted for public education due to their unique
storm water impacts.
' Commercial and industrial property owners, grade school children, and adults are being targeted for basic
stormwater education. These groups are being targeted to ensure a basic understanding of non -point
source pollution and its impacts on the environment throughout the community. City leaders also aspire to
provide these groups with,basic pollution prevention techniques they can easily implement into their
everydav lives.
' Grade School Children
Traditionally, standardized testing in public schools has focused on language, grammar, and mathematics
' knowledge. Consequently, schools have concentrated less of their educational efforts on other subjects,
one of which is science. Recently, standardized tests have begun including sections that specifically target
the students' knowledge of science. In order to keep their students fully prepared, teachers and
administrators must now find and prepare appropriate science -oriented material and lessons.
The City does not currently have any efforts devoted to educating grade school children about water
quality issues. In order to instill a sense of individual responsibility for water quality with future
generations, school children should be directly targeted in the City's public education efforts. Programs
tailored specifically for children also have an educational "spillover" effect which reaches beyond just the
students. Parents, teachers, administrators, and officials are all exposed to the information in the progress
of developing, presenting, and learning the course material. With the increasing importance of science
March 2003 Gly of Burlington
Stormwaler Management Plan it
there i not likely a more appropriate and effective way t educate the public than in the
curricula, s ely to be oy o
classrooms of local schools.
Adult Education Efforts
The City does not currently have any efforts devoted to educating adults about water quality issues.
Adjustments to the curriculum would be required, but similar programs directed at school children could
also be used to educate adults. Some would argue that parents become educated through their children,
but additional literature needs to be tailored directly towards the adults in the City of Burlington.
Educating adults is generally regarded as much more difficult than educating children. However, it is
important that adults understand the numerous ways that they harm the quality of surface waters in
Burlington and how to prevent or reduce this pollution.
Commercial and Industrial Education Efforts
Commercial and Industrial businesses are being targeted for education to inform owners about the
' impacts of illicit discharges, reporting procedures, proper waste disposal practices, and the efforts they
can take to minimize pollutants from their sites.
1
fl
1
7.1.3 Target Pollutant Sources
The City of Burlington lies within Subbasins 03-06-02 and 03-06-03 of the Cape Fear River Basin.
Subbasin 03-06-02 contains the cities of Burlington, Greensboro, Graham and Mebane. There is a large
amount of agricultural land use in this subbasin, although the urban land use surrounding Greensboro and
Burlington has a great impact on water quality. Both point source discharges and nonpoint source runoff
contribute to the Fair to Poor water quality bioclassifications found in many streams in the subbasin.
Subbasin 03-06-03 contains few urban areas except along the 1-40/85 corridor between Burlington and
Greensboro. The primary land use in this subbasin is a mixture of agriculture and forest. Most water
quality problems are associated with nonpoint sources. Erosion from agricultural land may cause large
sediment inputs into streams within this subbasin. The worst water quality in the subbasin was observed
in Little Alamance Creek in Burlington. Urban runoff is the most likely cause of this low rating.
P,ihlir. ediir_.ation and outrear_.h nmP ams will attempt to address pollutants resulting from urban runoff
since that appears to be the major concern for each of these subbasins. In addition, the City will focus
efforts and activities on Little Alamance Creek to address those deficiencies.
7.1.4 Outreach Program
The possibilities for meeting this minimum measure are truly limitless and the City is encouraged to
develop their own new ideas. Presentations to civic groups, development of brochures and other literature,
and development of multimedia spots all qualify as public education efforts. The following items will
meet the requirements of this minimum measure:
Obtain, Develop, and Distribute Water Quality Educational Materials
There are numerous agencies with potential sources of information available on non -point source
pollution that could be utilized by the City. The NCDENR has developed educational materials that are
available on-line at,,vww.enr.state.nc.us/htnal/environmental education.html. Available information
includes environmental education materials, kids' pages, resources for teachers, and education plans.
Also, the Division of Water Resources administers two environmental education outreach programs,
Stream Watch and Project WET (Water Education for Teachers), Stream Watch is a stewardship program
March 2003 City of Burlington
5tormwater Management Plan 12
' i f behalf. Project WET is
whereby local citizens can adopt a waterway, or a portion one, el o o ,and act on its b Z o�ect
' a K-12 interdisciplinary water education program intended to supplement a school's existing curriculum.
Laundry, upholstery and carpet cleaning businesses, along with automobile service repair facilities, are
susceptible to producing illicit discharges (see Minimum Measure #3). Educational materials tailored to
' these industries will be produced and distributed to appropriate businesses operating within the City.
The City can modify this existing material or create its own to make the information most relevant to
local situations and concerns. The materials must be located in conspicuous places where they are
available to citizens throughout the City. Appropriate sites include City buildings, parks, and public
lakefront areas.
' Water and Sewer Utility Billing
The City of Burlington bills water and sewer customers either monthly or bimonthly. Dissemination of
water quality education notices could be done through the utility billing, which is a good source of
contact. Upon investigation, the City's post card billing has limited space to include water quality or
other information. Should the City elect to change to a different type of mailer the potential for utilizing
this medium would be greatly enhanced.
City Web Page
Internet access is widely available, making it a prime vehicle for disseminating information of any kind to
a large audience. The City's web page, located at www.ci.burlington.ne.us, is already well designed, with
a simple layout and relevant information for the citizens of Burlington. A portion of the web page will be
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web sites discussing storm water quality, public education and involvement, and illicit discharges will be
constructed.
' City Works and Burlington Employee Newsletter
Another public education mechanism that the City already has in place is the City Works newsletter and
the Burlington Employee (BEN) newsletter. Published four times a year, the City Works community
newsletter is mailed to every utility customer in the City. It contains information about local events, City
meetings, recreation opportunities, local officials, and department activities. A series of articles in
upcoming issues will heighten awareness of storm water and water quality issues. BEN is a newsletter
distributed to all City employees that will also be used to deliver water quality information.
Government Access Television
The City produces a television show, At Your Service, once a month. The show highlights areas of interest
in local government. A show will be produced that discussed storm water and water quality issues. The
channel also utilizes an electronic bulletin board that can be used to broadcast public service
announcements informing the public of the importance of proper storm water management and present
ways in which citizens can participate in water quality -related activities.
Stormwater Hotline
' The City will implement a stormwater hotline for its residents. The hotline will enable residents to tail in
concerns related to water quality or quantity. This hotline will enable residents to be involved in
reporting water quality violations, illegal dumping, or other issues.
r,
March 2003 City of Burlington
5lormwater Management Plan 13
I
1
7.1.5 Decision Process
' The City of Burlington realizes that most of its citizens do not have a basic understanding of non -point
source pollution and its impacts on the environment. It is the goal of City leaders to educate the public
' about these issues by targeting specific groups as well as the population as a whole with basic information
about water quality and pollution prevention techniques using various mechanisms, including brochures,
presentations, and other media outlets.
7.1.6 Evaluation
The success of the public education program will not be easy to measure. The number of households
targeted with information, the number of people attending educational forums, the number of
presentations given to various groups, or the number of hits on the City's storm water web page are all
. good indicators of how many people are being reached in the community. The completion of the tasks
1ietPrl in the RMP sllmmary tahle. ditrinn the ve.ars shnwn will he used as an indication of success.
I
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1
7.2 Public Involvement and Participation
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community's storm water management program. As a result, the NPDES Phase II program will require
the City of Burlington to encourage public participation and involvement in the City's storm water
program. The public is to be given opportunities to play a substantial role in both the creation and
imnlementntion of the management program- LTsina the nublic to heln develon the nrosrram will help to
broaden public support, increase the number of potential ideas to meet the permitting requirements, and
shorten the implementation schedules due to fewer public outcries and dissent.
According to the Phase 11 Temporary Rules, at a minimum the City may comply with North Carolina G.S.
143-318, the open meetings law to meet the requirements of minimum measure #2. However, this
compliance does not equal public participation and involvement, because open meetings do not
necessarily involve any public input. Therefore, the.City will be required to determine appropriate best
management practices and measurable goals toward encouraging public participation and involvement.
Potential opportunities for public participation and avenues for involvement are abundant, as discussed in
the following section.
7.2.1 BMP Summary Table
0.1vYr+`1!M easuiable Goals
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Advisory Board
Establish a Storm Water Advisory
X
Gary L. Hicks I
Board
Public Works Dir.
2
Volunteer Programs
Implement volunteer "Adopt A
X
Gary L. I -licks /
Watershed" and "Adopt A Stream"
Public Works Dir.
programs
3
Storm Drain
Implement a program to stencil City's
X
X
X
X
Gary L. I -licks I
Stenciling
known storm inlets (coordinate with
Public Works Dir.
inventory)
I
I
I
r March 2003 City of Burlington
■ 5tormwater Management Plan 14
1
4
Environmental
Work with existing area
X
X
X
X
X
Gary L. Hicks 1
Groups
environmental groups (Haw River
Public Works Dir.
Group, Sierra Club) to coordinate
water quality efforts within the City,
including Big Sweep and Earth Day
activities
5
Household
Implement or coordinate with
X
Gary L. Hicks 1
Hazardous Wastes
Alamance County to provide a
Public Works Dir.
household hazardous wastes
and Don Davis /
collection day
Sanitation
Su erintendent
7.2.2 Target Audience
' The target audience for the public involvement and participation minimum measure includes all the
citizens of Burlington. Specific groups to be targeted include citizen volunteer groups (both children and
' adults), Boy Scouts and Girl Scouts.
7.2.3 Participation Program
7.2.3.1 Citizen Representatives on a Storm Water Management Panel
The City should make every effort to work with the community rather than just for the community. In
' . order to give the community a voice in storm water expenditures, the City will create a Storm Water
Advisory Board. The Board may include City employees, concerned citizens, and local business
representatives. The Board will provide input toward effective methods of educating the public on the
importance of proper storm water management and pollution prevention methods. Meetings will be well
publicized in advance in order to increase public attendance.
' 7.2.3.2 Public Hearings
The City currently complies with North Carolina G.S. 143-318, the open meetings law. All meetings are
advertised and are open to all citizens. Appendix C contains the agenda for the March 4, 2003
Burlington City Council meeting where a resolution was passed to submit the NPDES Permit application
and Stormwater Management Plan.
7.2.3.3 Working with Citizen Volunteers
Ir Big Sweep
■ Big ,Sweep is held on the third Saturday of every September in communities throughout North Carolina.
i9 Big Sweep is conducted by volunteers statewide to clean up North Carolina waterways. In Alamance
County Big Sweep takes place along the Haw River. In 2001, 800 volunteers including school groups,
. Boy and Girl Scouts, and other organizations removed approximately 24,000 pounds of refuse. The City
I T1___l.__..1..____ ]_] >>_1 r i r
ux lain iiii�wss �iuviueu cquipMt;ni and iaaor for the refuse material. i nis event promotes water quality
efforts and provides educational opportunities for the citizens of Burlington and will be continued.
' Earth Day
Barth Day, a :;'orld:v.de e ent held eve. j yea+ iu AEriii, celebrate t►ic JLCUui'S uniuidI U1LVUonulc11t.
' Groups around the world organize events each year to raise awareness of environmental issues and
sustain public commitment to environmental protection. The Burlington Parks and Recreation Department
E
March 2003 City of Burlington
Stormwater Management Plan 15
sponsored an Earth Day celebration at City Park in April 2001. The celebration was open to the public
' and information distributed included information pertaining to the tree planting program, refuse collection
and recycling programs, and potential stream restoration projects within the City. The Earth Day
celebration will be continued and possibly expanded to include more water quality information.
1 Citizen Environmental Groups
There are several environmental groups within Alamance County working on water quality -related issues.
The Haw River Assembly and The Haw River Trail organizations are both concerned with issues related
to the Haw River. Other groups working within the County include The Elon Center for Environmental
Studies, the Elon Sierra Club, the Haw River Group of the Sierra Club, and the Burlington Beautification
Bureau.
Household Hazardous Materials Collection Day
■ The City will sponsor or work with Alamance County to co-sponsor a household hazardous materials
collection day in an effort to collect used oil, batteries and other common household hazardous wastes.
Examples include lawn and garden pesticides and fertilizer, paint and paint thinner, anti -freeze, brake
fluid, and gasoline and oil mixtures. This activity would likely reduce the amount of toxic chemicals
'.• entering the waterways of the City. Improper disposal of these types of contaminants is considered an
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minimum measure: Illicit Discharge Detection and Elimination (see Section 73).
7.2.3.4 Volunteer Monitoring or Stream Clean -Up Activities
The City will encourage citizens to participate in activities other than Big Sweep that will protect or
rehabilitate local waterways and drainage areas. These types of events can help meet both public
education and public involvement requirements as outlined by EPA. The City can develop programs to
suit its particular needs or can promote involvement in programs that are already in place. Some existing
programs that the City will possibly promote include:
Adopt -a -Stream
Man communities oversee a program that allows civic groups, neighborhoods, school classes and others
Y P !� �' P � � � ,
an opportunity to become active participants in the health of their local waterways. Similar to the "Adopt-
' • a -Highway" programs, volunteers select a waterbody and pledge to keep it clean. Usually, the group is
given recognition for its efforts on signs at bridge crossings or in city bulletins and newsletters.
' . Adopt -a -Watershed
ADO P(T•A
This organization seeks to "enhance K-12 science education and encourage watershed WATEk "
' . stewardship." Using a local watershed as a living laboratory, students engage in
hands-on activities, making science applicable and relevant to their lives. It weaves
education with the community by developing collaborative partnerships and
reinforcing learning through community service. www.adopt-a-watershed.org
1
Youth Organizations
' Several youth organizations offer programs that place an emphasis on environmental issues, some
specifically with water quality. The City will encourage the local chapters of these organizations to
' become active in these types of programs. A couple of examples include:
March 2001 Uty of Burlington
Stormwater Management Plan • 16
n
11
I
I
11
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1
Soil and Water Conservation Merit Badge
This project, offered in the Boy Scouts of America merit badge program, helps boys
understand the importance of water and soil conservation practices. It also requires that the
badge candidate become involved by conducting a project to help recover or preserve an area
whose soil or water is deemed sensitive. www.meritbadge.comfbsa/mb/i 06.htm
Water nrnn Patrh
This project was developed jointly by the United States EPA and the Girl Scout Council of
the Nation's Capital (GSCNC). It encourages girls to "make a difference in their communities
by becoming watershed and wetlands stewards." The program allows girls use their skills and
their knowledge to educate others in their community about the need to protect the nation's
valuable water resources. www.epa.gov/adopt/patchl
Storm Drain Stenciling
Due to the fact that most citizens are not well educated on the subject of surface
water quality, one public involvement activity that will help improve water
quality is to stencil City -owned storm drains. Many citizens are misinformed and
believe that storm drains flow to the City sanitary sewer system. Therefore, some
citizens dump contaminants such as used motor oil and anti -freeze into the storm
drains.
Various civic groups, such as the Boy and Girl Scouts, will be contacted in an
effort to get the community involved in the stenciling. Volunteers may also be
also be recruited using local radiSt V. orm di rans cbt an e sencilit ed wh varios
u
messages such as "Drains to Haw River" or "No Dumping, Drains to Stream". Other options include
nlactir nlntpe rnnvavinn cimilnr mpccnrrpc xvhirli ran ha crlsiprl rlirar thr to flip 'mite Tim- ("tv will lnnk at
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all options to develop the most effective stenciling program.
A similar activity, although more related to public education than involvement,
involves installing customized manhole covers. Numerous foundry companies
have begun customizing manhole covers for Phase I and Phase U communities.
The covers can be cast with the City of Burlington logo and could read "Sanitary
Sewer" or "Storm Sewer" to differentiate between the two. The City could choose
to retrofit existing manholes with a new customized cover or could mandate that
all new development be required to adhere to these standards. Many foundries
will offer customized covers for the same price as standard covers if a community
requires them as part of their standard specifications. The City will also
investigate the possibility of using these customized manhole covers.
7.2.4 Decision Process
The City of Burlington realizes that most of its citizens do not have a basic understanding of non -point
source pollution and its impacts on the environment, and therefore are not involved in activities to
March 2003 City of BuA!ngton
■ Slormwater Management Plan 17
1
improve water quality. It is the goal of City leaders to involve the public about these issues by involving
them in public meetings and volunteer opportunities.
7.2.5 Evaluation
The success of the public involvement program will not be easy to measure. The number of volunteer
opportunities sponsored by the City, the number of citizens attending open meetings, the number of storm
drains stenciled, and the number of citizens who are involved in volunteer clean up activities are all good
indicators of how many people are being reached in the community. The completion of the tasks listed in
the BMP summary table during the designated year will be used as an indication of success. The
responsible party listed for each activity will be held responsible for implementing the BMPs.
It a
7.3 Illicit Discharge Detection and Elimination
' To eliminate illicit discharges into the City's storm sewer system, the City of Burlington will be required
to develop a strategy to detect and eliminate such discharges. An illicit discharge has been defined by the
EPA as "any discharge into a separate storm sewer system that is not composed entirely of storm water".
Typically, illicit discharges enter a storm sewer system either through direct connections, e.g., sanitary
sewer piping, or indirectly from cracked sanitary sewer conveyance systems, spills collected by storm
drains, or from contaminants dumped directly into a sewer inlet. The following are typical examples of
illicit discharges:
• Sanitary wastewater
• Effluent from septic tanks
• Laundry wastewater
• Commercial car wash discharges
• Improper disposal of household or automotive toxics
• Spills from roadway accidents
Pollutants from these sources can include heavy metals, toxics, oils and grease, solvents, nutrients,
1 viruses, and harmful bacteria. Substantial levels of these contaminants can damage fish and wildlife
habitats, decrease aesthetic value, and more importantly threaten public health due to contaminated food
and drinking water supplies.
' To comply with NPDES Phase 11 program requirements, the City will be required to address the
following requirements:
i• Develop a storm sewer map illustrating the location of all storm sewer outfalls and the names and
location of all waters of the United States that receive discharges from these outfalls.
• Prohibit the discharge of non -storm water discharges into the City's storm sewer system through the
implementation of an ordinance or other regulatory mechanism.
• Develop a plan to detect and address non -storm water discharges, including illegal dumpinb.
• Educate public employees, businesses, and the general public regarding the impacts associated with
illegal discharges and the improper disposal of waste.
March 2003 City of Burlington
Stormwater Management flan 18
L�
1
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7.3.1 BMP Summary Table
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Storm sewer system
Develop storm sewer outfall map
X
X
X
X
X
Gary L. Hicks 1
map
Public Works Dir.
2
Illicit discharge
Develop a comprehensive ordinance
X
Gary L. Hicks /
ordinance
that addresses all aspects of illicit
Public Works Dir.
discharge location and elimination,
including monitoring requirements,
penalties, and prohibitions
3
Illicit discharge
Develop and implement a program to
X
X
X
X
X
Gary L. Hicks /
detection and
locate and address illicit discharges
Public Works Dir.
elimination
located during outfall inventory
4
Public education
Develop educational materials to
X
X
X
Gary L. Hicks /
inform the general public and targeted
Public Works Dir.
businesses about illicit discharges
7.3.2 Storm Sewer System Map
One of the major tasks associated with this minimum control measure is the development of mapping of
the City's regulated MS4 outfalls. Unfortunately, the City of Burlington does not currently have any form
of comprehensive documentation of the City's storm sewer system or the regulated outfalls.
The City of Burlington must develop a storm sewer map illustrating the location of all storm sewer
outfalls and the names and location of all waters of the United States that receive discharges from those
outfalls. EPA defines an outfall as "a point source at the point where a municipal separate storm sewer
discharges to waters of the United States". These waters of the United States generally include any
waterway that is identified on a USGS 7.5' topographic quadratic map. A map showing these waterways
within the city limits of Burlington is located in Appendix A.
The inventory of the City's outfalls will help the City gain awareness of their system and the location of
the discharge points. EPA recommends collecting all available existing information that may include
outfall locations such as City records, construction plans, and drainage studies and then field verifying
their locations. However, it is likely that most of the storm sewer system will not be identified on any
available form of mapping. In order to obtain a comprehensive map of the City's outfalls, it will be
necessary to walk the jurisdictional waterways and locate outfalls by visual observation.
A storm sewer system map will be developed that shows the location of all regulated outfalls and the
names and location of all receiving waters. These outfalls will be located and verified in the field using
GPS technology. The map will be regularly updated when new outfalls are located, either through
identification by City staff or through as -built submittals from developers.
r7.3.3 Regulatory Mechanism
In order to prohibit illicit discharges to the MS4, the City must adopt a new ordinance. The City will
create a new ordinance to address illicit discharges and connections. This ordinance will include
language that specifically relates to the requirements of the NPDES MS4 permit such as:
• Findings of fact
• Objectives
March 2003 City of Burlington
I5tormwater Management Plan 19
• Prohibitions
' • Notification of spills and violations
• Requirements for monitoring
• Inspections
• Penalties
7.3.4 Enforcement
The illicit discharge ordinance mentioned above will be implemented and enforced to ensure that illicit
discharges or connections are eliminated. This ordinance will require that violators address illicit
connections within a certain time frame or they will face penalities to be determined when the illicit
discharge ordinance is developed.
7.3.5 Detection and Elimination
The City of Burlington must also develop a program to detect and eliminate illicit discharges. In order to
detect non -storm water discharges, the City must develop a program and methodology for identification
of these discharges. EPA has determined that after a 72-hour time period of no rainfall, any discharge
from a municipal separate storm sewer may be non -storm water related. Therefore, unless the discharge is
exempt from the regulation, i.e. irrigation water, water line flushing, or residential car washing, the
discharge is considered an illicit. In order to determine the source of the discharge, grab sampling must be
performed during dry weather conditions. Regulated communities are then required to analyze the
constituents in the sample in order to determine the source of the discharge and to eliminate the
contaminant if it is an illicit connection or discharge.
The locations of the City's outfalls will be mapped using GPS technology linked to a Geographical
' information System (GIS) database. Attributes of individual outfalls such as shape, type, size, and
conditions will be recorded digitally as the outfalls are located. This data will then be incorporated into
the City's GIS.
The following sections include procedures and guidelines for tracking potential illicit discharges.
7.3.5.1 Procedures for Location of Priority Areas
Sanitary Sewer Issues
One of the most common and easily detectable types of illicit discharge is domestic wastewater.
Discharge from a cracked sewer line or a cross connection is usually associated with extremely
unpleasant odors and contains evidence that the common citizen will recognize. Therefore, unlike other
111_]a_ fthis _ f discharge t,g..l.,,..ally...,,...'.
1111G1L5, UGLCl:L1V11 ofthis type Vl ULJU110.1bG ILVGJ 1LVL b'G11G10.11y 1C.ti U11 c. �a�iipii��� iGt f+voiur�. �uwa�iuvu�wx..
However, wastewater illicits are a recurring problem. Despite proper design and construction techniques,
leaks will continue to occur due to old infrastructure, erosion, and numerous other means. The City of
Burlington, like virtually every other municipal wastewater system, has experienced some minor
problems.
The City of Burlington has taken steps to alleviate inflow and infiltration (1&1) into the wastewater
system. Although inflow to the system does not affect the quality of surface runoff, cracks that allow
inflow will also allow outflow should portions of the system become backed up or completely full.
Therefore, cracks in the sewer system increase treatment costs due to the treatment of storm water,
decrease overall plant capacity, and have the potential to endanger the quality of surface waters. In the
March 2003 City of Burlington
Stormwater Management Plan 20
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early 1990s, an I&I study of the system was performed. The City is proactively replacing and repairing
older sanitary sewer lines which has greatly reduced the number of overflows. The City has in place a
notification policy for any sanitary sewer spill or overflow. Each spill that reaches surface waters of the
State must be reported to the State.
Two common problems that have been identified in the City are I&I due to the use of clay pipe for much
of the older portions of the wastewater system infrastructure and numerous stream sanitary crossing
failures due to erosion around their respective pilings. Clay pipe contributes to I&I problems and
necessitates regular inspections (representatives of the City regularly walk the lines and the City's TV
truck is utilized for pipeline inspections). Erosion at stream crossings has become a problem due to
continual expansion and construction within the City limits. The addition of impervious area (rooftops,
sidewalks, paving, etc.) has increased both runoff volumes and peak flow rates. The increase in volume
and intensity of surface runoff has caused many major drainage ditches and creeks to erode or widen.
Field crews will take special care around sanitary sewer crossings to identify any possible illicit
discharges.
7.3.5.2 Procedures for Tracing Illicits
Outfall Inventory/Mapping
The EPA requirements for Phase I communities are to collect data on all existing outfalls 12" or larger in
industrial areas, and 36" and greater in all other areas. Ditches in industrial land use areas will be picked
up when their drainage areas are 2 acres or more. Ditches in all other land use categories will be included
>___ I_ a :w 1 a:� �.� +> cn rl,o ' .,. t, ,.,1 a include 'ttr;but. ^'t
W I1C.11 LIM 1110.111[LgG arras 1caling LV LLIC111 are JV acres or more, Tile iilvenlvl �' J11vuld � ..5
for the following: inspection date and time, site description, outfall size and material, discharge color,
discharge odor, presence and type of floatables, discharge turbidity, deposits/stains, vegetative condition,
presence or absence of flow.
Dry Weather Screening Procedures
The inventoried outfalls will serve as the basis for identifying the field screening areas. Dry weather
screening only takes place greater than seventy-two hours after a storm event greater than 0.1 inches. The
National Weather Service Stations should be consulted for rainfall quantities in the area, along with local
weather reports and rain gauges placed near the areas to be screened.
Only major outfalls with observed dry weather flow are required to be sampled. The status of flowing
outfalls should be integrated into the GIS outfall coverage.
Once an outfall is found to have a dry weather discharge, additional measures must be taken to determine
whether the discharge is illicit.
Illicit Connection Investigative Procedures
The illicit connections program is composed of a set of investigative procedures to determine if a dry
weather discharge is illicit and, if so, how to deal with it. Below is an overview of the illicit discharge
investigation procedures that will be used by the City.
1. Check each outfall for dry weather flow. Upon finding dry weather discharge or other evidence of an
illicit discharge (ie. odor, discoloration of surrounding area, etc.) perform a visual inspection looking
for those items listed below. Also check for odor, flow depth and flow quantity.
March 2003 City of Burlington
5tormwater Management Plan 21
2.
i
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1
Perform field testing for water temperature and pH and obtain a sufficient sample to test for total
chlorine, detergents/surfactants, phenols and copper. The site should be sampled again no less than
r t 1 1 1_ _� r1 n 1_ _ ._ 1
four hours ►ater, out no mule toad 24 hours later.
If, upon returning for the second sample, there is no flow, note as such and return the following day.
After three "no flow" conditions, and lacking additional evidence of an illicit discharge the outfall
may be removed from the potential illicit discharge list.
If flow continues on the second day, record the data in the Potential Illicit Discharge database.
Begin walking the contributing system upstream until flow is no longer found.
Check the watershed for facilities that may contribute the identified parameters found in steps I and 2
to determine a list of potential sources of the dry weather flow.
Inspect suspected facilities for potential illicit connections.
Notify owner of the facility of the potential violation, identify steps to be taken, and establish
schedule for removal.
9. Perform a follow-up investigation at the site to ensure that the illicit has been removed.
Visual Inspection Investigation
The initial investigation is based on visual inspection, including:
• Odor
The odor of storm water discharges will vary widely. Odor can be a good indicator of the type of
pollutant in the water. For instance, storm water discharges may smell like sewage, oil, gasoline, or
may contain a chemical smell. Decomposition of organic materials can also cause a distinctive sulfur
odor. Odors may vary greatly with changes in temperature and time of year.
• Color
Color can also be an important factor in determining the source of an illicit discharge. The particular
color should be noted and tracked upstream as far as possible. Sewage will typically have a gray or
brown color, whereas industrial wastes may have a variety of,colors.
• Turbidity
Turbidity is a measure of the amount of suspended matter in the water and affects the clarity of the
discharge. Discharges from industrial facilities are often highly turbid. Although erosion can also
create highly turbid water, this should not be the case during dry weather flows. Each inspection
should note the relative degree of turbidity.
0 Floatables
Floatables are solids and liquids that float on the surface of the water. Floatables may include
substances such as animal fats, food products, trash, oils, plant materials, solvents, foams, or
gasoline. Floatables can often lead directly to the manufacturing process or other source of the illicit
discharge. A full description of the type and quantity of the floatables and a photograph of the
discharge should be included in the report.
w March 2003 City of Burlington
■ Stormwater Management Plan
22
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• Residue
1
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1
Residue left on the conveyance system can be an indicator of an illicit discharge. Discoloration of the
pipe or channel should be tracked upstream. It is also important to note the location of the
discoloration or stain within the conveyance system. For example, is it just a line of residue half way
up the pipe or is the pipe completely stained for some depth?
• Vegetation
Vegetation growing in the immediate discharge area should be noted in relation to vegetation
moWinn in the rrenaral yirinity of the nutlet (_..ertain dICChATPPC Can C llse substantial changes In
--o '-
plant growth. Discharges containing a high nutrient content may cause increased growth while
discharges with severe changes in pH may cause a decrease in growth. Although vegetation patterns
may serve as an indicator of non -storm water discharges, they are also difficult to interpret. Time of
year, rainfall patterns, exposure to sun all affect plant growth and may be contributing factors to the
changes in vegetation patterns. Caution should be used when considering vegetation as an indicator
of an illicit discharge.
• Structural Damage
Like residue, structural damage to the conveyance system can also be an indicator of an illicit
discharge. Structural damage is typically more noticeable in concrete pipes. Acidic discharges may
cause cracking, spauling, or deterioration of the concrete. The location of the damage within the pipe
and the distance upstream will be important in determining the type of pollutant and the source of the
discharge.
Field Testing Investigation
In addition to visual inspection, field testing investigation may be performed to determine the source of
the illicit discharge. field testing should be done for the following characteristics:
- Temperat'ur e
Water temperature that varies greatly from the ambient air temperature is a good indicator that there
is an illicit discharge to the system.
I . pH
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The normal pH of storm water typically ranges from 6 to 7.5. Values outside of this range are an
indicator of an illicit discharge. Water with values of 3 to 6 are acidic and may indicate discharges
from textile mills, pharmaceutical manufacturers, metal fabricators and companies that produce
resins, fertilizers, or pesticides. Wastes containing sulfuric, hydrochloric, or nitric acids are a
common source of contamination. Water with values of 8 to 12 may indicate discharges from
industries such as the following; textile mills, metal plating facilities, steel mills, and producers of
rubber and plastic. Wash water used to clean floors and industrial machinery may also produce
alkaline wastewater.
March 2003 City of Burlington
Slormwaler Management Pian
23
• Copper
Elevated levels of copper may indicate discharges from cooling, boiler, or industrial re -circulation
systems. Copper sulfate is typically used as an algaecide in all of these systems. Copper can also be
' an indicator of discharges from an automobile manufacturing or maintenance facility.
• Phenols
Elevated levels of phenols may indicate industrial wastewater discharges. Caution should be
exercised, however, since phenols may also be present in other waste streams. Phenols should be
considered in relation to other parameters in determining the potential source.
+ SurfactantslDetergents
Typically, the presence of surfactants and detergents will indicate a connection to either an
automobile wash facility or a laundry facility. High surfactants/detergents and elevated temperatures
are good indicators of laundry facilities. Lower levels of surfactants/detergents may indicate a
connection to a residential laundry or industrial facility.
• Chlorine
The absence of chlorine may indicate a natural water source. However, due to chlorine's ability to
quickly dissipate, caution should be used when making judgements based on its absence. Generally,
only potable water sources will contain chlorine. Therefore, the presence of chlorine insures that the
source is not a natural water source. Very high levels of chlorine typically indicate connection to a
swimming pool.
' Using the results of the visual and field testing investigation, likely sources of the illicit discharge can be
identified. Typically, illicit discharges and connections are from either wash water or sanitary sewer
sources. The investigator will work upstream looking for the connections.
Additional testing may be required at upstream points and testing of additional parameters may also be
necessary to further identify the actual source. Other investigative methods that may be used include dye
testing, smoke testing, and in -pipe cameras.
Illicit connections may be verified by performing an on -site inspection. When on -site inspections are
performed, the inspection should be filly documented and photographs of the connection and facility
should be taken when feasible. After a potential source is identified, testing should be conducted
immediately upstream to insure that there are not multiple sources of the discharge.
Proceaures for Kemoving iliicits
Upon identification of the source of the illicit discharge or illegal dumping, the responsible party will be
notified to cease the improper practices. All appropriate regulatory agencies will be notified of the
discharge. ge. `AJ.. W, viola LUr play b-- filled ill a1.eVrdanee Willi the adiJptcd or dlLlallLe and VY 1li be glvelf a
designated period of time to eliminate the illicit connection by either:
a) rerouting the flow to the sanitary sewer (if appropriate),
b) constructing on -site treatment facilities,
c) permitting the connection (if applicable), or
d) removing the source of the illicit discharge.
March 2003 City of Burlington
. Stormwater Management Plan 24
During the designated period inspections may be conducted to verify compliance with the order to cease
and desist further discharges and any clean up procedures required to mitigate damages caused by the
discharge.
7.3.5.4 Procedures for Plan Evaluation
A debriefing will be held after the first drainage area is complete to discuss procedures and policies
associated with the detection and elimination process. Results of the investigation will be evaluated and
the process will be revised as necessary. The types of illicit connections found will also be considered to
determine the next highest priority_ watershed. For example, if it is found that the majority of illicit
connections come from a particular type of facility, the watershed with the highest concentration of that
type of facility will be investigated next. A debriefing will be conducted after each watershed
investigation is concluded. Additional meetings will be held, and changes to the process will be made as
appropriate.
7.3.6 Non -Storm Water Discharges
Some categories of non -storm water discharges include 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,
irrigation water, springs, water from crawl space pumps, footing drains, lawn watering, residential car
washing, flows from riparian habitats and wetlands, dechlorinated swimming pool discharges, and street
wash water. These categories of discharges are not presently seen as significant contributors of pollutants
to Burlington's MS4 system and therefore will not be addressed.
7.3.7 Other Incidental Non -Storm Water Discharges
Based on available information there are no other incidental non -storm water discharges that are
contributing significant amounts of pollutants to the MS4.
13.0 vuu earl i
Improve Illicit Education Efforts
The City will also be required to educate their citizens on the potential harms associated with the illegal
dumping of illicit,. The City will distribute literature on the detrimental effects of many household toxics.
Citizens will be made aware of what can and can't be dumped into the storm sewer system.
Representatives of the business community will also be informed using educational ideas discussed in the
Public Education section. Efforts such as this will help meet the illicit discharge education requirements,
and will correlate with minimum measures 1 and 2.
Storm Water Management Guide for Susceptible Businesses
Certain industries are susceptible to producing illicit discharges. A storm water management guide,
tailored to these industries, will be produced and distributed to appropriate businesses operating within
the City (See Public Education minimum measure).
7.3.9 Decision Process
The City of Burlington does not know the location of regulated outfalls within their jurisdictional area.
Therefore, it is the goal of City leaders to identify these outfalls and in turn identify, track and disconnect
March 2003 City of Burlington
. 5tormwater Management flan 25
1
1
any illicit discharges to the MS4. In addition, the public will be educated about illicit discharges and their
' impact on water quality in Burlington.
The illicit discharge detection and elimination process described previously is based on EPA guidance
and processes and procedures being used successfully in other communities. The process allows for a
timely and efficient gathering of information within each watershed and provides documentation of
potential discharges, facilities cited and actions taken. The debriefing meetings held at the end of each
drainage area investigation allows for further refinement of the system.
There are three basic reasons why illicit connections have been made to the system. These three reasons
are discussed below.
1. The person responsible for the discharge is unaware that it is happening. For example, a sanitary
sewer leak.
2. The person responsible for the discharge is aware of the discharge, but is unaware that it is
unacceptable.
3. The person responsible for the discharge is aware that the discharge is occurring and is aware that it is
unacceptable.
The first two reasons for illicit discharges wilt be addressed through education efforts and interagency
agreements. Regular inspections of each drainage area will also help to reduce the number of connections.
Generally, reduction in the number of discharges associated with the third type listed above will only be
reduced through aggressive inspection and enforcement activities.
7.3.10 Evaluation
The overall goal for this minimum measure is the identification and removal of illicit connections that are
negatively affecting water quality in the City of Burlington. In order to meet this goal, the storm sewer
map with all regulated outfalls located must be completed. The completion of this map will form one
measure of the program's success. The success of this minimum measure can also be measured through
the number of illicit connections that are identified and addressed. See the BMP Summary Table located
in Section 7.3.1 for more information.
7.4 Construction Site Stormwater Runoff Control
Polluted storm water from construction sites is often conveyed to storm sewer systems that ultimately
discharge into rivers and streams. Sediment from construction sites has been shown to exceed that from
agricultural lands by 10 to 20 times and 1,000 to 2,000 times for forested land. During a small storm
event, both large or small construction sites can contribute a significant quantity of pollutants to receiving
water bodies, Although sediment is the primary concern, contaminants include nutrients, pesticides, oils
and grease, concrete truck washout, and construction chemicals and debris.
NPDES Phase lI legislation requires the following to comply with this minimum measure:
• Establishment of an ordinance or other regulatory mechanism requiring the proper implementation of
sediment and erosion controls for construction sites with a land disturbance greater than or equal to
one acre.
• Procedures for site inspection and enforcement control measures
March 2003 City of Burlington
Stormwater Management flan 26
1
• Sanctions to ensure compliance with local regulatory requirements (Ordinance or other regulatory
1 mechanism)
• Implementation of procedures for site inspection and enforcement of sediment and erosion control
measures
The following sections describe the City of Burlington's erosion control program that is already in place.
The program meets the requirements of this minimum measure therefore no additional BMPs are needed.
However, the City of Burlington will pursue educational programs for employees and contractors.
Land Development Regulations
All land -disturbing activities involving an area greatcr than one acre are required by law in the state of
North Carolina to operate under an approved erosion control plan. This plan must be obtained before
work begins on a site. Although tracts containing less than one acre do not require permits, adequate
measures to prevent erosion and contain sediment on site are still required.
r
The City of Burlington Engineering Department, as the local enforcement agent for the control of land
disturbing activities for the state of North Carolina, administers an erosion control program within the
City limits and extraterritorial jurisdictional area. This program operates under the direction of the band
Quality Section of NCDENR, which enforces the requirements of the Sedimentation Pollution Control
Act of 1973 on a statewide basis.
The Sedimentation Pollution Control Act of 1973 is a performance -oriented law that allows flexibility in
determining the most economical and effective methods for controlling erosion and sediment. The North
Carolina Sedimentation Control Commission sponsored the development of the North Carolina Erosion
and Sedimentation Control Planning and Design Manual, a basic reference used during plan preparation,
review, implementation, and enforcement to minimize and control the effects of erosion and
sedimentation on surrounding land, water bodies and ecosystems.
Plans are required to be prepared by, or under the direction of, a Professional Engineer, Professional Land
Surveyor, Registered Architect, or Registered Landscape Architect. Since every site has unique
characteristics, each erosion and sedimentation control plan should be site specific. However, the Design
Manual contains a checklist of items to be incorporated into a typical plan. City of Burlington
Engineering Specifications and Standard Details are also available to assist the designer.
Three sets of drawings showing the site, its features, and the proposed erosion and sedimentation control
plan must be submitted to the Engineering Department for review. A completed Financial
Responsibility/Ownership Form and an acreage -based permit fee must be submitted with the proposed
plan.
Staff engineers review the plan and if it is found to be incomplete or inadequate the designer is requested
to provide additional information or to revise the plan. Once the plan is approved, a Land -Disturbing
Activity Permit is issued. During implementation of the plan and subsequent construction, Engineering
Department staff members inspect the site to determine if the approved plan has been implemented and to
ensure compliance with the law. Any person or party engaging in a non -compliant land -disturbing activity
will be directed to stop work and will be issued a Notice of Violation. Violators are subject to a fine of
$500.00 per day for each day that the site is not in compliance, and maybe charged with a Class 2
' misdemeanor, which may include a fine not exceeding $5000.00. Examples of violations include:
M No approved plan
• Failure to follow an approved plan
March 2003 City of Burlington
■ Stormwaler Management Plan 27
• Failure to provide adequate ground cover
• Insufficient measures to retain sediment on site
• Failure to take all reasonable measures
• Inadequate buffer zone
• Graded slopes and fills too steep
• Unprotected exposed slopes
• Failure to maintain erosion control measures
All measures should be installed as shown on the approved plan, and should be inspected by the
contractor or developer on a weekly basis and after all storm events.
Special Use Permits
The Technical Review Committee made up of City employees from various departments meets every
Thursday to review submitted plans that may be of concern because of their size or location. The
committee decides whether a Special Use Permit is necessary for the project, and what will be required
from the developer to control storm water runoff. The developers of large projects are encouraged to
provide for retention of storm water on -site through the utilization of basins, storage pipes and other
devices. Those projects for which the issuance of a Special Use Permit is necessary will generally be
required to implement retention measures if downstream properties would be adversely affected.
Floodplain Ordinance
The City of Burlington also utilizes a floodplain ordinance to restrict development within the FEMA
floodplain and other mapped streams where regulatory flood elevations or floodways have not been
provided. The ordinance sets forth requirements for development along both mapped and unmapped
streams.
Watershed Protection Regulations
Alamance County adopted watershed protection regulations that provides the authority to regulate the use
of properties in water supply watersheds located in its territorial jurisdiction by virtue of N.C.G.S. 153A-
330(ff) and Article 21 of Chapter 143 of the General Statutes of North Carolina. The ordinance includes
density limits, buffer regulations, site plan requirements, and penalties for violations.
Other Ordinances
In addition to the above -mentioned ordinances, the City of Burlington Engineering Department also
requires developers to submit calculations for proposed development adjacent to small streams. The
results of these calculations yield a minimum finished floor elevation that is allowed on the site.
7.5 Post -Construction Stormwater Management in New Development
p
and Redevelopment
Post -construction storm water management is necessary because runoff from areas undergoing
development and redevelopment has significantly impacted receiving waterbodies. This impact typically
occurs in two forms. The first impact is due to an increase in the type and quantity of pollutants in storm
water runoff. As water flows over these sites, it transports harmful contaminants such as oil and grease,
pesticides, heavy metals, and various nutrients, (e.g., nitrogen and phosphorous). These pollutants become
suspended in the runoff and are conveyed to receiving water bodies, such as lakes and creeks.
The second past -construction runoff impact typically occurs as a result of increased storm water runoff
rates and volume due to an increase in impervious surfaces. This increase in runoff has not only been
March 2003 City of Burlington
Stormwater Management Plan 28
�f
shown to interrupt the natural water balance of percolation into the ground, but also impact the receiving
waterbody through streambank scouring and downstream flooding.
The NPD> S Phase U program will require that the City of Burlington address the following requirements:
• Develop, implement and enforce a program to manage post -construction discharges to the MS4 from
new development or redevelopment project that disturb greater than or equal to one acre
• Develop and implement a combination of both structural and non-structural BMPs
• Create an ordinance or regulatory program that requires the use of post construction runoff controls
• Ensure adequate long-term operation and maintenance of the controls
The post construction program developed by the City of Burlington must be in place by March 10, 2005.
7.5.1 Storm Water Management Permitting Options
The City of Burlington's post -construction program will apply to all new development projects that
cumulatively disturb one acre or more, and to projects less than an acre that are part of a larger common
plan of development or sale. The program will also apply to all redevelopment projects that cumulatively
' disturb one acre or more, and to projects less than an acre that are part of a larger common part of
development or sale. The projects must apply for permit coverage as a low or high -density project.
7.5.1.1 Low Density Projects
The definition of low -density projects is given within SWU-268-103102. Within the City of Burlington,
there are few low -density projects as minimum zoning requirements allow for development that exceeds
these thresholds.
7.5.1.2 High Density Projects
Criteria for high -density projects (projects that exceed the low -density threshold) are also given in the
State's instructions for Preparing the Comprehensive Stormwater Management Program Report (SWU-
268-103102). Within the City of Burlington, most of the high -density development is occurring within
several areas of the Citv. The area of the Citv currently exoeriencine the most erowth is the southwest
fringe area, which will be served with City water and sewer service and will include a new highway
interchange. The new development includes commercial, residential and industrial land uses.
7.5.2 Operation and Maintenance
In order for the post -construction program to be successful, an operation and maintenance component
must be developed that ensures the long-term operation of required structural BMPs. A requirement will
be developed as part of the post -construction ordinance that requires owners of permitted structural BMPs
to submit an annual maintenance inspection report on each structure. The requirement will also specify
that the inspections must be conducted by qualified professionals and that the inspection report must be
signed and certified by the owner. Failure to comply with this requirement will result in penalties adopted
as part of the post -construction ordinance.
7.5.3 Control of Fecal Coliforms
Water polluted by human or animal waste can harbor numerous pathogens that may threaten human
health. Since routine tests for individual pathogens are not practical, fecal coliform bacteria are widely
used as an indicator of the potential presence of disease -causing microorganisms. Fecal coliforms are
March 2003 City of Burlington
0Storm .. ----erne-.
awoiiiwdier ividiiay�i��e�u radii 29
bacteria typically associated with the- intestinal tract of warm-blooded animals and their number is
* generally assumed to be correlated with the number of pathogens in a water sample. They enter surface
`�"^ ••,,, }'PT ^f sources '^rlt:dir:n falling nn_�,te �uactecuater cvctrmc hrnken sewer lines,
waters uvw a numbe v sources including � � •--••,
improperly treated discharges of domestic wastewater, improperly designed or managed animal waste
facilities, and wild animals.
Several general management strategies for addressing fecal coliform contamination include:
• Maintenance and repair of sanitary sewer lines by WWTP authorities.
• Elimination of piped unpermitted discharges of home waste (also ]mown as "straight piping").
• Encouragement of local health departments to routinely monitor waters known to be used for body
contact recreation (e.g., swimming and tubing).
There are no waterbodies impaired for fecals within the City of Burlington. However, septic tanks are
used in the City where citizens live outside of the service area of the wastewater treatment plant. Within
. the City of Burlington, the Alamance County Heaith Department, Environmental Services, is responsible
_ for permitting new septic tanks within the County, and also for issuing repair permits to repair or replace
existing septic systems. The City of Burlington will continue to rely on the Alamance County Health
Department to perform these tasks as related to fecal controls.
The City of Burlington has the authority to require residents with failing septic systems to tap onto the
City's sanitary sewer system.
01
7.5.4 Additional Requirements for SA Waters
There are no SA waters within the City of Burlington. Therefore, these requirements do not apply.
7,5.5 Additional Rngwiremen4e fnwe r Tow"% Wa}pry
There are no designated trout (Tr) waters within the City of Burlington. Therefore, these requirements do
not apply.
7.5.6 Additional Requirements for Nutrient Sensitive Waters
There are currently several waterbodies within Burlington that are classified as NSW according to data
available from NCDENR. These waterbodies include Little Alamance Creek, the Haw River, and Back
Creek. According to the Cape fear River Basinwide Assessment Report of June 1999 and other
information available from the DWQ website both point and nonpoint source runoff (agriculture and
urban) contribute to poor water quality in the region.
The City of Burlington is currently required to remove phosphorus from its wastewater effluent that is
discharged into the Haw River. The limit imposed is 2 mg/L and will likely change with the development
of the Upper Cape pear nutrient management strategy devised by NCDENR. The process is currently
underway with NCDENR and the entire Upper Cape hear River watershed to determine the nitrogen
limits. This process will not be complete until 2005. The City of Burlington will coordinate with these
efforts in order to develop the most effective program to address nutrients.
Urban runoff is the likely cause for the water quality issues in Little Alamance Creek. The Haw River
receives a large amount of wastewater discharge, and fecal coliform bacteria are noted as a problem
parameter. According to DWQ, a TMDL and management strategy will be developed to address fecal
March 2003 City of Burlington
Stormwater Management Plan 30
coliform bacteria and turbidity, and resampling for biological and chemical data will attempt to determine
potential problem parameters associated with nonpoint sources in the flaw River. Back Creels also
receives wastewater discharges, and the 1996 plan recommended that no new discharges should be
permitted. DWQ will continue to monitor this stream to assess potential impacts frorn point and nonpoint
sources.
The City of Burlington proposes to address these issues on a watershed basis. Areas with NSW will
require site -specific BMPs to reduce nutrient loadings in these watersheds. These BMP requirements will
be implemented and enforced as part of the comprehensive post -construction ordinance to be developed.
75.7 Comprehensive Watershed Plans
A The City of Burlington plans to split the City into smaller management units (based on drainage area).
The areas will then be prioritized for investigation based on any identified water quality impairments or
e heavily developing areas. The areas will then be evaluated separately to determine the most effective
BMPs (structural or non-structural) to be implemented in each area based on the types of development
occurring and any water quality concerns, including NSW.
t 7.5.8 BMP Summary Table
I
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1
I
lw_m�
s"iralile Ii
IMM5131"aamME
i
f
lY>r
7r
Yt ¢
i Xr
csponsible t'n
1
Post -Construction
Develop and implement a post-
X
X
Jim Lauritsen 1
Ordinance
construction ordinance by March 2005
City Engineer
that addresses both high and low -
density projects and BMP
requirements as well as requirements
for nutrient sensitive waters
2
Fecal Coliform
Coordinate with Alamance County
X
X
X
Robert Harkrader
Control
Health Department to develop a
/ Planning Dir.
program to address pollution from
septic tanks
3
Nutrient Sensitive
Coordinate with efforts to develop and
X
X
Steve Shoaf /
Waters
implement a nutrient application
Utilities Dir.
management program through the
Upper Cape Tear nutrient management
strategy
4
Non -Structural
Provide training for developers and
X
X
X
Jim Lauritsen /
BMPs
City staff
City Engineer
5
Structural BMPs
Develop BMP manual
X
X
Jim Lauritsen I
City Engineer
6
Operations and
Develop operations and maintenance
X
X
X
X
X
Jim Lauritsen /
Maintenance
requirements for BMPs (to be included
City Engineer
in the ost-construction ordinance
March 2003 City of Burlington
Stormwater Management Plan 31
I
7.5.9 Non -Structural BMPs
At +.,� I n1L,tn + rh r t A ,, ,Aaf"-- r •d,'ater rn� ,,,r o� �t tha �.,,L,•en
110ri-JLILIGLl11a1 J>lYll s are management L1AeasureJ LlIa+L prevent ueg uuuLA VAA va LL..V ua v•..u v .v...a v,
rather than treating runoff that has already been polluted. Non-structural practices can include a variety
of site -specific and regional practices, including street sweeping, illicit connection location and
elimination, public education and outreach, land use modifications to minimize the amount of impervious
surface area, waste collection, and proper materials storage. While non-structural practices play an
invaluable role in protecting surface waters, they are not as easily quantified as structural BMPs.
7.5.9.1 Policies and Ordinances
In the City of Burlington's Zoning Code, the Water Supply Protection Regulations apply to any
Watershed Critical Areas (WCA). Within any WCA, a 50-foot stream buffer on each bank is required on
all perennial streams, and a 100-foot wide natural buffer is required around all water supply reservoirs.
The City of Burlington may explore the possibility of implementing a buffer ordinance in other areas of
!' the City.
s! 7.5.9.2 Policies and Ordinances to Encourage Infill Development in Higher -Density Urban Areas
The City of Burlington does not currently have or plan to have in the future any policies or ordinances to
encourage infill development in higher -density urban areas.
7.5.9.3 Education Programs
An important piece in the post -construction program is training for developers. Since they will be the
persons most affected by these new post -construction regulations, it is imperative that they have a good
understanding of what will be required with the new regulations. The City of Burlington will provide
�i informal training for developers on the new regulations and design requirements. The training will take
place before the new regulations are implemented.
7.5.9.4 Other Measures
Hazardous Materials
The City of Burlington Fire and Police Departments are first respondents to a spill. The City of
Burlington has a reciprocal agreement with the City of Graham Fire Department. The Department serves
as the Hazardous Material (Hazmat) response team that is in charge of mitigation of potential
' contaminants during a spill. The Graham Hazmat response team is backed up by NCRRT4 (the State
Regional Hazmat team). Since most spills are due to roadway accidents, hazardous materials commonly
end up in the storm sewer system. The Department is responsible for keeping the material from spreading
to additional areas or to nearby storm drains. After dikes or other methods confine the spill, a private
.t a I._.._ 11 a a a:
contractor V[ ULfIGI agency IJ GVlltal�teU tV L.1Gall up, I+V llGGl, aAlu U1J}1VJe VI Ll lti 111a LGL la I. 111G 1J L11 A l Il rr LV I
Public Works Department utilizes their Spill Prevention and Control and Countermeasure Plan in the
event of a spill at the Equipment Services Center.
7.5.10 Structural BMPs
Structural BMPs are physical structures designed to remove pollutants from storm water runoff, reduce
downstream erosion, provide flood control, and promote groundwater recharge. Structural BMPs differ
from non-structural BMPs in that they include engineering design and construction.
March 2003 City of Burlington
Stormwater ivianagement clan 32
11
The City of Burlington will recommend appropriate structural BMPs for each individual drainage area
within the City based on the types of development that are currently taking place and any water quality
issues that exist within the area. It is anticipated that recommended BMPs will include wet detention
ponds, wet extended detention ponds, storm water wetlands, shallow wetlands, pond/wetland systems,
bioretention areas, sand filters, infiltration trenches, and enhanced dry swales. A BMP manual listing
BMP options and details will be assembled for use by City staff and developers.
7.5.11 Regulatory Mechanism
�5
It will be necessary for the City of Burlington to develop an ordinance to address post -construction
runoff. Tile ordinance will include r ,Uirementc fnr low and l-ilah density nrniects, operations and
r-
maintenance requirements, and structural and non-structural BMP requirements. This ordinance will be
developed in accordance with the schedule presented in the BMI` Summary Table.
7.5.12 Operation and Maintenance of BMPs
Long-term maintenance of BMPs is essential for program success. Therefore, the City of Burlington will
develop, as part of the post -construction ordinance, a long-term operation and maintenance plan for
BMPs. The City will explore the possibility of an up -front fee for developers in order to pay in advance
for maintenance of BMPs. The City is concerned that it will be difficult to enforce an agreement made
with developers to maintain BMPs annually, and that it would take much staff time and effort to ensure
the maintenance was taking place. Instead, the City may take on the maintenance of the facilities
themselves and require developers to pay in advance for this service. The City will explore their options
and include in the post -construction ordinance the operation and maintenance plan that is determined to
be the City's best option.
7.5.13 Decision Process
NPDES Phase lI requirements have necessitated the development of a post -construction storm water
management program for the City of Burlington. The City currently has no post -construction
�1 requirements in place, and City leaders have made it a priority to have a fully functional program in place
by March 2005. Even though this is a tight deadline to achieve th% Cite iS lu]]" wi]lir. toa' ^fP
y y b appropriate the
required staff and resources to meet this date.
The first step in development of the program will be to prioritize the drainage areas within the City.
These areas will be investigated and master planning of each area will provide specific information about
I different areas of the City. This will allow City planners to designate any specific priority areas for the
program. In addition, the master planning activities will allow for area -specific BMPs to be implemented.
Once the areas have been identified, a decision path will be created to select appropriate BMPs.
jAn important part of this program will be training, both for City staff and for developers. Since these
regulations are new and many have had no experience with them, training will begin early in order to
ensure that all individuals affected by the new regulations have had sufficient training.
7.5.14 Evaluation
The main measure of success will be the development and implementation of the post -construction
program by the accelerated deadline of March 2005. The development of a comprehensive ordinance will
be another measure of success, since it will involve many different individuals from various departments.
f, March 2003 City of Burlington
IStormwater Management Plan 33
Other measures of success will be the completion of program tasks within the designated year for
completion. For a detailed outline of measurable tasks refer to section 7.5.8.
7.6 Pollution Prevention/Good Housekeeping for Municipal
Operations
The final minimum measure required by the NPDES Phase H program involves the examination and
possible alteration of municipal operations for good housekeeping and pollution prevention measures.
This measure requires that municipalities evaluate their actions to ensure a reduction in the amount and
type of pollution that accumulates on streets, parking lots, open spaces, and storage and vehicle
maintenance areas that discharge into local waterbodies. In addition, this measure requires an evaluation
of results from land development actions that may contribute to pollutants in storm water runoff. The
primary intent of the EPA with this measure is to improve and protect water quality by altering the
performance of municipal operations. However, the EPA also feels that this measure could also result in
increased cost savings for municipalities through proper and timely maintenance of storm sewer systems.
To comply with this control measure, the City will be required to address the following requirements:
r • Develop an operation and maintenance program with the objective of preventing or reducing pollutant
runoff from municipal operations into the City's storm sewer system.
• Include training of City operations personnel on how to incorporate pollution prevention / good�J _
housekeeping techniques into City operations. This could include park and open space maintenance,
fleet and building maintenance, new construction and land disturbances, and storm water system
maintenance.
I
Guidelines for implementing these measures could include structural and non-structural measures to
reduce floatables and other pollutants, controls for reducing or eliminating the discharge of pollutants
from areas such as roads and parking lots, maintenance and storage areas (including salt/sand storage and
snow disposal areas), and waste transfer stations.
7.6.1 BMP Summary Table
;g1,
1.11MMEN'�$M>'
�,, u WIN
Q tMeasurable Goa11
m.�
Yr
Yr
Yr
Yx
Res oiaible
�
.,,
�`I2uE"3ii
4Y5"Pa"i
/lLosit�cinti
1
Training
Provide good housekeeping / pollution
X
X
Gary L. Hicks 1
revention training for staff
Public Works Dir.
2
Maintenance and
Development of a program to inspect
X
X
X
Gary L. Hicks /
Inspections
and repair City -owned storm drainage
Public Works Dir.
infrastructure
3
Vehicular
Purchase combination sewer cleaner
X
Gary L. Hicks /
Operations
truck
Public Works Dir.
4
Other Operations
Apply for NP—DES industrial permit
X
Gary L. lucks i
coverage for the Public Works fleet
Public Works Dir.
maintenance facility and wastewater
and Steve Shoaf 1
treatment facilities
Utilities Dir.
[
n.a:
._;rULnanccs
or.1inancPs ill 4PPPl
X
and amended as necessary
4
I
#
I
Public Works Dir.
March 2003 City of Burlington
iStormwater Management Plan 34
7.6.2 Affected Operations
Maintenance Facilities
The City of Burlington maintains several maintenance facilities. These facilities include athletic
maintenance, recreation maintenance, public works (building maintenance), equipment services,
sanitation department, street department, and water and wastewater facilities. The City currently recycles
used motor oil, antifreeze and parts washing fluid from City fleet vehicles. In addition, oil filters are
drained before they are landfilled. Used batteries are exchanged with a local battery vendor, and other
recyclables (plastic, cardboard, paper) are collected by the City. The City utilizes an oil -water separator at
a.. C....:1;�„ Fueling t t;onc� are nni.nr- and no materials a e ctnn-d
1[5 WdiCI $IlU $GWer Jy�telfl li1a 111LGna11l G la4il u�. i u�uu� $tutivxw urn •vvyi.0
outside uncovered.
Existing Municipal NPDES Permits
The City of Burlington maintains NPDES permit coverage for its municipally owned industries. Due to
initial NPDES legislation in the 1970s and 1980s, the East Burlington and South Burlington Wastewater
Treatment Plants and the City's water treatment plant were required to obtain NPDES permit coverage.
The East Burlington WWTP NPDES permit number NCO023868 currently covers treated effluent from
the wastewater treatment plant. The South Burlington WWTP is covered under NPDES permit number
NCO023876. Wastewater from the potable treatment process at the water treatment plant is covered by
NPDES permit number NCO083828.
7.6.3 Training
The City must establish a training program for their staff regarding the importance of storm water
pollution prevention and good housekeeping. Currently City staff members receive no specific good
housekeeping training. Rather, most practices are learned on the job. EPA recommends training for staff
members who deal with parks and open space, the fleet maintenance center, new construction, and NIS4
maintenance. A group program will be presented to City staff members regarding good housekeeping
practices and procedures. In addition, available resources and materials from the EPA and NCDENR will
be used where appropriate for training.
7.6.4 Maintenance and Inspections
Storm Drainage Policy and Procedures
The City is responsible for maintenance of storm drainage systems that fall within their rights -of -way. In
addition, the City maintains a policy to address storm drainage issues in subdivisions and on private
property. It is the City's stance that storm drainage systems in new subdivisions are the entire and sole
responsibility of the developer. In addition, all new subdivisions are required to have drainage systems
' installed by the developer in accordance with the requirements and regulations of the City. Pipe sizes are
determined by the engineer and then approved by the City's Engineering Department.
The City maintains a cost -share program that allows property owners receiving storm water discharged
from an existing City street to share in the cost of installation of storm drainage improvements on their
property. Residents provide an easement to the City and share in the cost of the project on a 50 — 50
percent basis. The City's maximum share of the cost of any project is $10,000 per lot or owner.
Street Sweeping
The goal of the City of Burlington's street sweeping prograrn is to address both aesthetic and water
quality issues. The goal is accomplished by distributing various levels of service throughout the business
�. March 2003 City of Burlinqton
Stormwater Management Plan 35
�l
and neighborhood community areas. The central business district, which has considerable vehicular and
pedestrian traffic, is swept twice per week. Heavily traveled commercial districts, City parking lots and
major through streets are swept once per month. Residential streets, with limited throughway and
pedestrian traffic, and neighborhood streets, which are used for local purposes only, are swept 2-3 times
per year. The street -sweeper also has an attachment to clean catch basins that can be utilized if needed.
it Pesticide/Herbicide Application
As part of the street sweeping program, herbicides are used to eliminate grass and weeds in the street and
curb line. The spraying is done in conjunction with street sweeping through a specialty designed closed
mixed sprayer. The City is environmentally conscious and does not use any restricted -use pesticides in its
program. Records are maintained to keep track of days and areas of application. Additionally, herbicides
are stored in safe, dry places in accordance with the manufacturers suggested recommendations.
Inventory and appropriate MSDS documentation are maintained. The pesticide/herbicide application
program utilized by the City of Burlington is licensed by the State of North Carolina.
7.6.5 Vehicular Operations
As mentioned above, the City currently recycles used motor oil, antifreeze and parts washing fluid from
City fleet vehicles. In addition, oil filters are drained before they are landfilled. Used batteries are
exchanged with a local battery vendor, and other recyclables (plastic, cardboard, paper) are collected by
the City. The City utilizes an oil -water separator at its water and sewer system maintenance facility.
Fueling stations are covered and no materials are stored outside uncovered.
D outiiie .maintenance _fa �tvrin ue ::'er s"item rem C:.YP$ that nine and e!!l �fertc hP kent free of riehric and
J 1 `rr r
blockages. This allows the system to operate at its full capacity and reduces the chances of road and
structure losses due to flooding. Specialized trucks, such as those manufactured by Vactor, are necessary
in removing blockages and preventative maintenance. The City has been considering a purchase of such a
truck in its 5-year capital improvement plan. The truck can also be used for sanitary sewer maintenance.
7.6.6 Waste Disposal
Wastes from municipal operations, including sweepings and dredge spoil are occasionally stored at the
public works maintenance facility. The amount of storage time is minimal, and the materials are taken
either to an approved landfill or an inert debris site. However, while the materials are kept on the site
they are not covered. The City will investigate options of either covering the piles or storing them in an
enclosed location until they are ready for disposal.
7.6.7 Flood Management Projects
Flooding is not a major concern in Burlington, in part due to the City's implementation of the Floodplain
Ordinance and strict regulation of development in floodplain areas. As a result, the City has not and does
not currently plan to construct any flood management projects.
7.6.8 Existing Ordinances
The City of Burlington's Code of Ordinances contains several sections that relate in some way to storm
water. These sections include: Chapter 13, Garbage and Refuse; Chapter 31.5, Soil Erosion and
Sedimentation Control; Chapter 37, Waters and Sewers, Chapter 17, Lakes, Chapter 32, Streets and
Sidewalks; and Appendix B, Floodplains. In addition Burlington has in place a Floodplain Ordinance and
IWatershed Protection Regulations (see Appendix D). The Sediment and Erosion Control Ordinance
s March 111, City of Burlington
�- 5tormwaier Mdrlagellenl Plan 36
1
I
regulates runoff resulting from site development and is also included in Appendix D. Also included in
Appendix D is the City of Burlington's existing storm drainage policy and procedures.
7.6.9 Other Evaluations
Although not directly related to the MS4 permit coverage required for the City of Burlington, the City is
required to obtain separate NPDES stormwater permits for the City's fleet maintenance facility and the
City's wastewater treatment plants. Municipally owned industries other than airports, landfills, and power
plants in small municipalities (<100,000 citizens) were exempt from NPDES permit coverage under the
Intermodal Surface Transportation Efficiency Act of 1991. The Phase 11 regulations eliminate the
"reir;nne PXPmnt ctnfiic nlie to the mfiire. of thework assor_.isted with a tynical city fleet maintenance
facility, these facilities can be viewed as a threat to water quality or a contributor of storm water
r discharges associated with industrial activity. In addition, the stormwater discharges from wastewater
treatment facilities are also subject to the Phase II regulations. The City of Burlington is required to
submit a Notice of Intent for the fleet maintenance facility and the wastewater treatment facilities by
March 10, 2003.
7.6.10 Decision Process
The City of Burlington realizes that implementing a successful storm water quality program affects all
levels of municipal operations. Therefore, City leaders are committed to devising and implementing a
Good Housekeeping 1 Pollution Prevention Program to address municipal operations. City programs and
y operations will be evaluated, illicit discharges located on City -owned properties will be addressed,
existing ordinances will be evaluated and altered as needed, and necessary training will be provided for
staff. See the BMP Summary Table in Section 7.6.1 for more information.
7.6.11 Evaluation
1
P111
I
t
As stated above, the BMPs listed in the Pollution Prevention/Good Housekeeping BMP Summary Table
located in Section 7.6.1 will be evaluated annually for compliance. In addition, the number of staff
members trained annually will be submitted as part of the annual report. Also included in the annual
reports [[1 the rcacrcr'1%ed year will bc, the I;laiiienance prQg'iaiu developed lvr JLunn drainage
infrastructure and the number and types of deficiencies corrected.
March 2003 City of Burlington
5tonmwater Management Plan 37
r
I
A PlD 1VnTY A
USGS Regulated Streams in the City of Burlington
0
t
I
1