03a_NCS000250_HSP_Business_Plan_FY2019

Highway
Stor T1water
HSP Business Plan FY 2019
Prepared by:
AECOM Technical Services
1600 Perimeter Park Drive, Suite 400
Morrisville, NC 27560
Prepared for:
NC Department of Transportation
Hydraulics Unit
1590 Mail Service Center
Raleigh, NC 27699-1590
919.707.6700
and
NC Department of Transportation
Roadside Environmental Unit
1557 Mail Service Center
Raleigh, NC 27699-1557
919.707.2920
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Page Intentionally Left Blank
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Table of Contents
ExecutiveSummary....................................................................................................................................... 1
1.0
Background and Mission of the Highway Stormwater Program..................................................1-1
1.1 Regulatory Drivers...........................................................................................................1-1
1.2 Goal and Vision of the HSP..............................................................................................1-3
2.0
HSP Organization..........................................................................................................................2-1
3.0
Planning Procedures and Objectives............................................................................................3-1
3.1 Short -Term Planning Procedures.....................................................................................3-1
3.1.1
Baseline Budget............................................................................................................................3-1
3.1.2
Vision Documents.........................................................................................................................
3-1
3.2 Long -Term Objectives......................................................................................................3-2
3.3 Maintaining Program Flexibility.......................................................................................3-2
4.0
Financial Management.................................................................................................................4-1
4.1 Funding Sources and Restrictions....................................................................................4-1
4.2 Budget Planning Procedures............................................................................................4-2
5.0
General Approach to NPDES Compliance and Program Areas.....................................................5-1
5.1 Routine Communication with NCDEQ and Other Regulators..........................................5-1
5.2 Short -Term and Long -Term Planning...............................................................................5-1
5.3 Compliance Reporting and Renewal Process..................................................................5-1
5.4 Management of Program Areas.......................................................................................5-1
5.5 Emerging Issues...............................................................................................................5-1
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List of Tables and Figures
Table 1.1. NCDOT Activities Authorized under NPDES Permit # NCS000250, effective October 1,
2015.........................................................................................................................................
Figure 1.1. Timeline of NCDOT's NPDES Permit..............................................................................
Figure 2.1. HSP Collaborative Management Organization..............................................................
Table 2.1. Responsibility Matrix for NPDES Permit Compliance......................................................
Table4.1. HSP Funding Sources.......................................................................................................
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1-2
2-1
2-3
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List of Acronyms
BMP
Best Management Practice
GREEN
Guided Reduction of Excess Environmental Nutrients
HOW
High Quality Waters
HSP
Highway Stormwater Program
HU
Hydraulic Unit
IDDEP
Illicit Discharge Detection and Elimination Program
LSC
Limited services contract
MS4
Municipal Separate Storm Sewer System
NCAC
North Carolina Administrative Code
NCDEQ
North Carolina Department of Environmental Quality
NCDOT
North Carolina Department of Transportation
NCSU
North Carolina State University
NPDES
National Pollutant Discharge Elimination System
ORW
Outstanding Resource Waters
PCSP
Post -Construction Stormwater Program
REU
Roadside Environmental Unit
SCM
Stormwater Control Measure
SPPP
Stormwater Pollution Prevention Plan
STIP
State Transportation Improvement Program
TIP
Transportation Improvement Program
TMDL
Total Maximum Daily Load
USEPA
United States Environmental Protection Agency
WBS
Work Breakdown Structure
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Executive Summary
This business plan documents the management procedures for North Carolina Department of
Transportation's (NCDOT's) Highway Stormwater Program (HSP). The HSP was established to support
compliance with various regulations associated with stormwater control and runoff from NCDOT's
activities, especially those associated with the Department's National Pollutant Discharge Elimination
System (NPDES) stormwater discharge permit (NCS000250). The NPDES permit authorizes NCDOT to
discharge stormwater runoff from general roadways including weigh stations and tolling facilities,
construction activities disturbing greater than one acre, borrow pits/waste piles, industrial facilities,
office buildings, rest areas, and NCDOT-owned railways. Activities conducted by the North Carolina
Turnpike Authority are covered under this permit, as well as the public education requirements for the
Global Transpark Authority's NPDES permit through a 2012 memorandum of agreement with that
agency.
The business plan provides an overview of the management structure of the HSP, including detailing its
funding sources and the responsible business units within the Department. A summary of its decision
making protocols and its estimated annual budgetary needs are also provided. Additional information, if
needed, is available from the HSP staff and on the internal HSP website.
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1.0 Background and Mission of the Highway Stormwater Program
The mission of the North Carolina Department of Transportation (NCDOT) is connecting people and
places safely and efficiently, with accountability and environmental sensitivity to enhance the economy,
health, and well-being of North Carolina. To achieve this mission relative to stormwater quality, NCDOT
has established the Highway Stormwater Program (HSP) to support compliance with various regulations
associated with stormwater control and runoff from NCDOT's activities.
This business plan documents the practices of the HSP in order to:
• Sustain the management structure of the program through potential program changes,
• Provide summary of current funding, and
• Identify strategies to maintain sustainable sources of funding for the HSP in addition to
maintaining compliance with stormwater-related regulations.
Applicable stormwater and water quality regulations have been promulgated by United States
Environmental Protection Agency (USEPA) and North Carolina Department of Environmental Quality
(NCDEQ). USEPA has determined that stormwater can impact water quality, the environment, and
public health, due to its potential to carry pollutants into receiving streams. Therefore, regulations have
been established to mitigate the potential effects of stormwater runoff due to development (including
highways). NCDOT is subject to Federal and State stormwater regulations requiring structural control
measures (SCMs, such as infiltration and retention systems) and non-structural controls (such as
housekeeping and training) to avoid, minimize or mitigate for impacts to stormwater quality due to the
Departments activities, listed in Table 1.1. SCMs are also known as structural best management
practices, or BMPs.
1.1 Regulatory Drivers
The primary source of stormwater and
water quality regulation addressed by
the HSP originates from the
Department's National Pollutant
Discharge Elimination System (NPDES)
Permit (No. NSC000250), first issued in
1998 and subsequently reissued in 2005,
2010, and 2015 (see permit timeline in
Figure 1.1).
NCDOT is regulated under the NPDES
program because it fits the definition of
a large municipal separate storm sewer
system (MS4) as set forth in the Clean
Water Act.
Table 1.1. NCDOT Activities Authorized under NPDES Permit
# NCS000250, effective October 1, 2015
• General roadway including weigh stations and tolling facilities
• Construction activities disturbing greater than one acre
• Borrow pits/waste piles (including mines)
• Industrial facilities with the following activities
o Ferry terminals and maintenance
o Vehicle and equipment maintenance
o Pesticide and fertilizer storage
o Salt and deicing chemical storage
o Material storage areas
o Asphalt and concrete plants (NCDOT owned and
operated only)
o Rail maintenance
• Non -roadway non -industrial facilities (i.e., office buildings and
rest areas)
• General railway
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Figure 1.1. Timeline of NCDOT's NPDES Permit
-June 8, 1998 - May 31, 2003 (administratively extended through March 31, 2005)
• Based on Phase I NPDES regulations and best professional judgement (BPJ) of NCDEQ.
• Heavy focus on Industrial Activites, such as county maintenance yards
HSP Business Plan
-April 1, 2005 - March 31, 2010 (administratively extended through September 9, 2010)
• Incorporates new Phase II NPDES regulations and expands emphasis on internal and external education, erosion and
sediment control, inspection and maintenance of post -construction controls, and the retrofits program.
-September 10, 2010 - September 9, 2015
• Increased focus on the Post -Construction Stormwater Program (PCSP) and internal and external (public) education
-Clarified non -road activities (i.e. offices and rest areas) are included under permit
• Coverage expanded to include Turnpike Authority
• October 1, 2015 - September 30, 2020
• Removed Encroachment Program
• Re -confirmed importance of Educational, Industrial Activities, Inventory, and PCSP Programs
• Expected period: October 1, 2020 - September 30, 2025
• Must reappy 180 days prior to expiration of Term IV permit
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NCDOT is also subject to additional rules and regulations issued by other state and federal agencies,
including Falls Water Supply Nutrient Strategy (15A NCAC 02B .0281) and Jordan Water Supply Nutrient
Strategy (15A NCAC 02B .0271).
1.2 Goal and Vision of the HSP
The primary goal of the HSP is to develop and implement a sustainable business model to support
ongoing compliance with the NPDES permit and to support stormwater and water quality -related needs
of the Department. These needs include environmental permitting, design, construction, and
maintenance of structural controls, development and implementation of nonstructural controls,
education, outreach to contractors (regarding specific topics such as the PCSP and Toolbox), and
reporting. Wherever possible, up-to-date research and new directions in stormwater and water quality
regulations from NCDEQ and USEPA will be incorporated.
Therefore, the guiding principles of the HSP are:
(1) Comply with NPDES Stormwater Permit requirements by managing, and minimizing stormwater
pollutants from permitted activities, including most notably roadway systems and industrial
areas;
(2) Design sustainable programs that can be effectively managed, implemented, and integrated into
NCDOT; and,
(3) Develop solutions that improve program delivery that are proactive, form partnerships, have
technical merit, and are fiscally responsible.
To implement its goal and vision, the HSP produces and provides to the Department a wide range of
materials for both internal and external consumption. Materials used internally by staff and contractors
are often intended to act as guidance to be applied using the best professional judgment of the
practitioners. To implement the guidance, the HSP provides training to practitioners implementing
stormwater and water quality controls on behalf of the Department, including contractors and State
employees in the Division and central offices. The HSP also develops tools such as checklists, forms,
standard operating procedures, training videos/materials, and web -based applications to aid the
Department. Most documents prepared under the HSP are available on the NC Connect website or
www.NCDOT.gov.
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2.0 HSP Organization
The HSP is collaboratively managed by NCDOT's Hydraulics Unit (HU) and Roadside Environmental Unit
(REU) with support from others including NCDOT's consultant partners, Division personnel, and
Research & Development staff and researchers (see Figure 2.1). NCDOT's primary HSP consultant,
AECOM Technical Services (AECOM), assists with HSP program planning and implementation. Other HSP
consultants provide support for various HSP permit programs. Additional NCDOT business units and sub -
consultants are incorporated as needed to address unique project tasks or workloads. The HSP
consultants facilitate a significant portion of the development of guidance documents and training
material under the oversight of the HSP staff.
To meet the goals of the HSP and the requirements of NCDOT's NPDES Permit, the HSP collaborates with
external entities including established researchers to facilitate investigations required under the HSP
Research Program. Additional collaborators include the regulatory community, primarily NCDEQ. The
HSP staff coordinates regularly with NCDEQ representatives to promote understanding and maintain
compliance. Through this structure, HU and REU coordinate the direction and long-term planning for
the HSP, and jointly participate in maintaining compliance with NCDOT's NPDES Permit.
Figure 2.1. HSP Collaborative Management Organization
Highway Stormwater Program
NCDEQ Roadside
Hydraulics Unit Environmental
Unit
NCDOT Research NCDOT groups including:
Consultants
& Development
• Highway Division
• Ferry Division
• Rail Division
• Global Transpark (External
Education only)
Researchers . Turnpike Authority
• Other Units
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The HSP also receives in -field implementation support from other NCDOT staff, making it a Department -
wide initiative (See Table 2.1). With a few exceptions, the different program areas of the HSP shown in
Table 2.1 effectively mirror the NPDES Permit sections. Each program area is led by technical staff in the
business unit having the most responsibility and authority to implement the requirements, with support
and implementation from other business units. Table 2.1 indicates the primary, supporting, and
implementing business units by the respective P, S, and I letters in the matrix. Additional information
about staff roles for each HSP program areas is available in a document entitled 'Roles and
Responsibilities for Implementing DOT's NPDES Permit No. NCS000250'. Maintenance of this document
is a requirement of the permit per Part III Section A.S.
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Table 2.1. Responsibility Matrix for NPDES Permit Compliance
HSP Business Plan
HWY
Permit Section
Description
HU
REU
DIV
RD
FD
DMV
NCTA
Section A
Illicit Discharge Detection and
S
P
I
I
I
I
I
Elimination Program
Section B
Post -Construction Controls
B. 1
Stormwater System Inventory
P
S
and Prioritization Program
B.2
BMP Retrofits
P
S
I
I
I
B 3
BMP Toolbox for Post-
P
S
I
I
I
I
Construction Runoff
B 4
BMP Inspection and
S
P
I
I
I
I
Maintenance Program
B 5
Post -Construction Stormwater
P
S
I
I
I
I
I
Program
B.6
Vegetation Management
P
I
I
I
I
I
Section C
Construction
C.1
Sediment and Erosion Control
S
P
I
I
I
I
I
Program
C 2
Borrow Pit and Waste Pile
P
I
I
I
Activities
C.3
Construction and Borrow
P
I
Pit/Waste Pile Activities
Section D
Industrial Facilities
Develop, Maintain, and
D.1
Implement Stormwater Pollution
P
I
I
I
Prevention Plans
Stormwater Pollution Prevention
D.2
Plan Requirements for Industrial
P
I
I
I
Activities
D.3
Qualitative Monitoring
P
I
I
I
Section E
Education and Involvement
Program
E.1
Internal
P
P
I
I
I
I
I
E.2
External
P
P
I
I
I
I
I
Section F
Research and Program
P
P
Assessment
III, Section C
Total Maximum Daily Load
P
S
I
I
I
I
Falls/Jordan Water Supply
GREEN
P
S
I
I
I
I
Nutrient Strategy
P - Primary Lead HU - Hydraulics Unit
S — Supporting REU - Roadside Environmental Unit
I — Implementer HWY DIV - 14 Highway Divisions
FD - Ferry Division RD - Rail Division
DMV - Division of Motor Vehicles
NCTA - NC Turnpike Authority
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There are other entities (such as public/private partnerships) that NCDOT coordinates NPDES permit
compliance activities with that are not shown in Table 2.1. This collaborative staffing approach to the
HSP enables the program to leverage the institutional knowledge within NCDOT to execute proactive
and inventive projects in a timely and cost-effective manner. Additionally, this organizational approach
allows the HSP to develop guidance and training materials that work within the operational structure of
the Department and for various end users including Division personnel, consultants, regulators, and the
general public.
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3.0 Planning Procedures and Objectives
Planning for the HSP takes into consideration the need for tangible results to maintain compliance with
stormwater quality regulations; effective budgeting of costs and manpower resources; and delivering
results that work with the mission, goals, and structure of the Department. Therefore, short-term and
long-term planning objectives are developed for each unique program under the HSP as well as for the
overarching Program. Additionally, the HSP maintains a degree of flexibility to respond to requests from
regulators, the general public, and ongoing Department projects.
3.1 Short -Term Planning Procedures
The HSP staff revised its short-term planning process to focus on activities to be performed within the
next fiscal year. In order to provide short-term planning and management for goals, funding, and staff,
the HSP staff reviews and updates this business plan annually or as needed. Part of this process is to
establish a baseline budget for expected expenditures for each program area. Additionally, HSP staff
develops individual Vision Documents for each program area for detailed planning; each Vision
Document is reviewed and updated annually or as needed and is maintained on the HSP internal
SharePoint site.
3.1.1 Baseline Budget
The HSP staff establishes a baseline budget annually as a planning tool to assist in the prioritization of
projects within each program area. The baseline budget is estimated in conjunction with developing the
Vision Documents.
Costs for NCDOT staff salaries in the Hydraulic unit and construction costs and staff salaries for BMPs are
included in the budget to for the HSP. The remaining funds are assumed to be available for contractor
support for each program area. An evaluation of previous expenditures of the HSP is made and used in
conjunction with expected future changes to each program area in order to develop an estimated
baseline budget for each program area. These baseline budgets are used to assess, prioritize, and
approve proposed projects from the Vision Document process that is described in Section 3.1.2 below.
A mid -year review is conducted as needed to revisit the budget status (i.e., verifying the remaining
program budgets are adequate to address any changing compliance concerns). If necessary, the
budgets or projects will be adjusted. At the conclusion of the fiscal year, the annual baseline budget is
verified prior to initiating the subsequent Vision Document review cycle and Business Plan update for
the next fiscal year.
3.1.2 Vision Documents
Writing and maintaining the HSP program area Vision Documents is a collaborative effort between
NCDOT HSP staff and AECOM as appropriate. Each Vision Document follows a standard outline that
includes the following information:
• Permit -term Goals — list of goals for the current NPDES permit term, focus on compliance with the
management measures required by the permit, and other stormwater quality regulations;
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• Compliance Strategy — general description of previous compliance achievements and the approach
for maintaining compliance of the specific program area in the future;
• Communication Plan — discussion of general communication needs and approaches to communicate
with NCDOT management, NCDOT staff and contractors, NCDEQ, and the general public;
• Education Approaches — discussion of educational needs and opportunities for both internal and
external audiences;
• Other Program Area Integration - discussion of how the program area interacts with other program
areas in order to facilitate collaboration and make effective use of manpower and other resources;
• Resources Needed — discussion of needed skill sets; and,
• Proposed Projects — a running list of tasks intended to meet goals and management measures,
estimates for NCDOT and consultant manpower, consultant costs, start dates and end dates, and a
description and problem statement (reviewed and approved by HSP staff prior to implementing a
task order for consultants).
HSP Vision Documents are intended to be living documents that are updated periodically to reflect
changes in program direction or compliance strategy. Generally, only minor updates are expected some
sections, including the Communication Plan, Education Approach, Integration with Other Programs, and
Resources Needed sections, unless the update year coincides with a new permit issuance, in which case
more comprehensive updates may be needed.
Proposed project ideas are developed by AECOM program managers through collaboration with NCDOT
program managers. Once project ideas are identified, AECOM program managers develop problem
statements and project descriptions for review with HSP staff. Projects are assigned priority status for
subsequent review in the context of the comprehensive program needs and available budget. AECOM
program managers assign projected budgets to approved projects, which are designated as either
SMART (specific, measurable, attainable, realistic and timely) or Top Priority SMART projects (SMART
projects that are especially critical). Through a final review, proposed projects are evaluated in light of
available budget and overall program benefits, and final approval is provided to selected projects. The
Vision Documents are then finalized and a permanent copy kept. Projects approved in this fashion are
flushed out with a detailed scope and budget and issued through Task Orders based on a schedule
suggested in the Proposed Project list. HSP staff reviews each Vision Document annually or as needed.
3.2 Long -Term Objectives
Given the potential for changing regulations and the dynamics of Department needs and initiatives, the
HSP maintains broad long-term objectives to 1) stay informed of regulatory and policy changes; 2)
continue communication with NCDOT staff, contractors, and the general public and provide them with
useful tools; and 3) plan for program growth and transition beyond the current permit term. HSP staff
also evaluate any emerging issues that may impact NCDOT's approach to stormwater quality and that
could require modifications to or input from the HSP.
3.3 Maintaining Program Flexibility
While planning and maintaining objectives are crucial for compliance with stormwater regulations, the
HSP also maintains flexibility to respond quickly to requests from NCDOT management, regulators, and
the general public. For example, the general public may submit a request for a presentation at a
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community event, or complaints may be made regarding NCDOT activities that appear to impact
stormwater quality. Requests from NCDOT management, regulators, and the general public require
quick, courteous, and knowledgeable responses. To address these needs and maintain flexibility, the
HSP:
• Implements limited service contracts (LSC) with prequalified contractors. This support structure
allows the HSP to quickly respond to requests, such as producing NCDOT land -use cover data
requested by regulators;
• Provides ad hoc consultation to assist other NCDOT staff with specific projects, such as selecting an
appropriate BMP for a road widening project; and,
• Maintains open communication and periodic meetings with regulators in general and on specific
projects to stay aware and prepared for regulatory changes.
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4.0 Financial Management
This section will discuss the funding sources and the HSP's budget planning procedures. As noted in
Section 3 of this plan, budgetary limitations are considered by HSP staff when developing and
maintaining the HSP.
4.1 Funding Sources and Restrictions
Funding for the HSP comes from a wide range of sources. Management and development of the HSP is
predominately funded from three sources:
1) Work Breakdown Structure (WBS) 34625.1.1 under Transportation Improvement
Program (TIP) R-4436,
2) WBS 36068, and
3) WBS 36057.
Other business units that support compliance with stormwater regulations contribute funding to the
HSP. Additionally, other sources of funds are periodically available. Table 4-1 summarizes sources of
funding for the HSP.
Table 4.1. HSP Funding Sources
R-4436, "NPDES Permit, Retrofit Sites to Protect Water Quality"
• Pre- FY15 Source: State Transportation Program; 80% Federal, 20% State funds
• Budget: $3,000,000 annually from 2016 — 2025 per current State Transportation Improvement
Program (STIP)
• Uses: Staff salaries (predominately for HU staff; other business units [such as the Divisions,
Geotech, Locations and Surveys] use when working on BMP retrofits or other HSP tasks), material
expenses for retrofit construction, administrative overhead charges, and consultant support.
• Managed by: HU
WBS 36068, "Stormwater Management"
• Source: Legislative line item
• Budget: approximately $500,000 annually
• Uses: Staff salaries (predominately for REU staff, material expenses for publications for public
education, administrative overhead charges, and miscellaneous compliance -related needs.)
• Managed by: REU
WBS 36057, "SPPP Compliance for Maintenance Yard"
• Source: State funds for maintenance
• Budget: approximately $500,000 annually, varying based on need
• Uses: Significant or one-time maintenance tasks for stormwater BMPs, development of
Stormwater Pollution Prevention Plans (SPPPs) and maintenance for water quality protection at
maintenance facilities (such as installation or upgrade of salt storage equipment)
• Managed by: REU
Periodically -Available Funds
Occasionally, additional funds are made available through partnerships, collaboration with other
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NCDOT business units for mutual benefit, or through other federal- or state -driven initiatives.
Examples include:
• Facilities Management periodically supports upgrades at industrial sites, such as connection of
sanitary sewer systems at NCDOT industrial facilities to support connecting wash racks to
municipal sanitary sewers.
• Grants and partnerships with non -profits may support internal or external education and retrofit
projects.
• Office of Communication supports development and distribution of external education materials.
• Research and Development supports research projects required by the permit.
• Activities such as Erosion and Sediment Control and Vegetation Management are performed by
REU.
• Litter Management office supports External Education outreach efforts.
• American Recovery and Reinvestment Act of 2009 supported construction of several retrofits.
• Legislative line items for specific projects, such as the Bridge Stormwater Project of 2009 — 2010
(TIP M-0418).
• Partnerships with municipalities to construct or maintain BMP retrofits.
Routinely Leveraged Funds
Funding and activities from other NCDOT business units contribute to the Department's compliance
with stormwater regulations. Although the resources from these units are not specifically categorized
or tracked for stormwater uses, reduction in these sources would impact the success of the HSP.
Although this list is not exhaustive or complete, examples include:
• Divisions are responsible for or participate in the inspection and maintenance of structural BMPs,
implementation of nonstructural BMPs such as street sweeping, identification and reporting of
illicit discharges and illegal dumping, pollution and litter removal, and pollution prevention at
industrial facilities.
• Design, implementation, inspection, and reporting of erosion and sediment control requirements
are supported through individual construction projects as well as REU.
• Management and reporting pesticide, herbicide, and fertilizer application are services routinely
performed by REU.
• Review and permitting of encroaching entities is done by the Utilities Unit
• Development and maintenance of information technology services provides information
management and analysis tools utilized by HSP.
• Development of internal and external educational materials and tracking of training provided to
NCDOT staff is provided by several Department units.
4.2 Budget Planning Procedures
In general, the HSP budget provided by R-4436 is allocated for each program area in consideration of the
status of permit compliance or need for additional development and support, as discussed in Section 3
of this business plan. Program areas with stable and established implementation techniques, such as
the Illicit Discharge Detection and Elimination Program (IDDEP), may not require significant effort.
Other programs may be stable but require routine and ongoing outreach, such as the Industrial
Activities program and the Internal and External Education Program. And some programs, while mature,
require significant efforts to support ever-expanding project locations, such as the BMP Retrofits and
Total Maximum Daily Loads (TMDL) Programs.
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The Proposed Projects list included in the Vision Documents described in Section 3 are used for ongoing
short-term budget planning to provide a relative level of effort associated with each upcoming project.
A detailed review of the level of effort for each project or consultant task order is made prior to
initiating a new project.
When selecting projects, HSP staff balance the need with the expense, seeking the greatest
environmental benefit for the cost. Additionally, some program areas such as Vegetation Management
and Construction are funded and performed by other business units as part of their core practices.
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5.0 General Approach to NPDES Compliance and Program Areas
Compliance with the Department's NPDES Permit requires ongoing planning and implementation for
each program area as well as proactive communication within the HSP and between the HSP and
NCDEQ. This section discuses several HSP compliance strategies.
5.1 Routine Communication with NCDEQ and Other Regulators
NCDOT and NCDEQ, along with other regulating agencies, generally maintain a collaborative
environment which enables regular interaction to review and assess the compliance status of the HSP.
HSP staff meet regularly with NCDEQ staff responsible for issuing NCDOT's NPDES permit. The meetings
between HSP staff and NCDEQ staff typically entail a review of ongoing efforts to maintain compliance
with the permit, focusing on one or two permit areas each meeting. HSP staff also interact with other
agencies regarding other regulatory drivers as needed.
5.2 Short -Term and Long -Term Planning
Detailed planning is performed through the Vision Documents developed for each permit program area.
On an annual or periodic basis, HSP staff will identify the approach to be taken to comply with the
management measures, measureable goals, objectives and other requirements of the permit, and to
update the Vision Document(s) as needed. Additionally, HSP staff hold weekly and/or monthly calls with
HSP primary consultant to review upcoming tasks and other management concerns.
5.3 Compliance Reporting and Renewal Process
HSP staff maintain a compliance calendar to track due dates for required submittals mandated by
NCDOT's NPDES Permit such as the Annual Report. In preparation for the next renewal permit
application, HSP staff maintain a list of preferred permit changes and expected impacts for the next
permit cycle. Tracking these requirements and long-range permit needs promotes ongoing compliance
and the issuance of a reasonable and achievable permit during the next permit term.
5.4 Management of Program Areas
The Department's NPDES Permit is segmented into program areas reflecting USEPA's Phase II
stormwater regulations and other requirements established by NCDEQ. Therefore, the HSP has been
organized in line with the permit, and each program area is managed by NCDOT business unit(s) with
the greatest level of involvement. Within each program area, individuals from the Department and from
consultants are selected to provide levels of expertise that will allow the development and
implementation of effective and reasonable procedures to maintain compliance. Each program area is
discussed in more detail in the Vision Documents maintained on the internal HSP SharePoint site.
5.5 Emerging Issues
The HSP assists the Department in maintaining compliance when responding to stormwater-related
regulations and other requirements by providing the Department and its contractors with support and
guidance materials. Regulations regarding stormwater management continue to change on a national
and statewide level. Therefore, the HSP must remain aware of pending changes that may affect the
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Stormwate HSP Business Plan
Department and, where feasible, provide input on the regulatory development so that stormwater-
related activities of the Department are represented fairly and with scientific accuracy. HSP staff
continue to evaluate and discuss emerging issues that have the potential for imminent or developing
impacts to the Department. HSP staff track these emerging issues and then coordinate with regulators,
Division management or Division staff and contractors as needed.
5-2 Version 4 — October 2019