03b_NCS000250_Example_Vision_Document-Industrial_Activities

HSP-IA - Vision Document
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NCDOT > HSP > HSP-IA > HSP-IA - Vision Document
HSP-IA IRMA BMP Guidance Manual
Vision Document
Industrial Activities Training Site Div 9 Bridge Cleaning
Vision Document Overview - Industrial Activities
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In order to provide long-range planning and management of goals, funding and staff, this program area has developed a Vision Document constructed over several pages on this Share Point
site. The Vision Document is intended to be a collaborative effort between NCDOT, AECOM, and appropriate specialty consultants. Goals for developing the vision documents include:
• Priority Management: Defined projects will allow for the prioritizing of new requests based on current priorities.
• Structure the activities of the program for the next 12 months (planning horizon to be determined by the Program Area Managers).
• Develop, describe, and prioritize projects needed to maintain compliance with the permit.
• Develop, describe, and prioritize projects that address NCDOT mission statement, goals and values.
• Develop, describe, and prioritize projects needed to make the program sustainable with effective tools and resources — long-term sustainability in the program through the permit term.
• Estimate skill sets needed and workloads for critical staff (NCDOT, AECOM, and others).
Timing and Updates:
Vision Documents should outline projects for a planning horizon determined by the Program Area Managers. They should be updated on an annual basis or as needed.
The planning horizon for the Research and Assessment Program is 12 months.
Revision Number
Revision Date
Revision Summary
0
July 31, 2012
Incorporate NCDOT comments and updated template
1
June 1, 2013
Incorporate NCDOT comments and finalized Vision Document
2
December 15, 2014
Incorporated NCDOT comments into Vision Document
3
June 8, 2015
Updates to Proposed Projects list FY2016; minor updates to other
pages. NCDOT comments incorporated and Vision Document
archived.
4
June 30, 2016
Updates to Proposed Projects list FY2017; minor updates to other
pages; updated Term IV permit requirements. NCDOT comments
incorporated and Vision Document archived.
5
April 25, 2017
Updates to Proposed Projects list FY2018; minor updates to other
a es. Compliance status check completed.
6
May 14, 2018
Updates to Proposed Projects list FY2018; minor updates to other
a es. Compliance status check completed.
7
April 9, 2019
Updates to Proposed Projects list FY2018; minor updates to other
a es. Compliance status check completed.
Format:
The Vision Document should be a "living" document that can be updated and maintained as needed. The Vision Document will be integrated into the Share Point site for each respective
program. This allows for collaboration, quick reference, and streamlining work as tasks can be assigned to staff once approved. After the Vision Document is approved, a pdf will be
created stored on SharePoint.
Development Process:
AECOM Program Area Managers will draft the program goals and proposed projects, pulling from conversations previously held with NCDOT staff and AECOM knowledge of other programs
and needs. Collaborative meetings with NCDOT staff and with other Program Area Managers will be held as necessary to develop and document the information. The AECOM Project Managers
will review the proposed information.
AECOM will notify the NCDOT Program Area Manager and Project Managers that the suggested information is available for review. Approximately one to three weeks after notification, AECOM
and NCDOT Program Area and Project Managers or their delegates will meet to collaboratively discuss and update the information.
Once approval for the proposed projects is provided, task orders for the approved projects will be drafted. At that time, the schedule and proposed projects will be finalized, along with budget
tracking.
The Vision Document consists of:
• An introduction to the program located on the homepage
• Permit -Term Goals guide the program to meet the HSP Guiding Principles and the objectives and measureable goals in the NPDES Permit
• An organization chart of Program Area Managers and a contact list of all program area participants on the homepage
• Proposed Project List, which includes proposed SMART projects and project ideas for review and approval by NCDOT staff and references projects that have been approved and
incorporated into Task Orders
• Communication Plan to discuss how the program area will communicate with stakeholders
• Education Approach to discuss how internal and external educational components will be implemented
• Integration with Other Programs, which documents the relationship between the Industrial Activities Program and other HSP program areas
• Resources Needed, which lists staffing, material/equipment, and other needs
Industrial Activities Program Overview:
The focus of NCDOT's Highway Stormwater Program (HSP) Industrial Activities (IA) Program is to develop and implement stormwater pollution prevention plans for NCDOT industrial facilities
and to provide stormwater pollution prevention training for NCDOT personnel. NCDOT's IA Program was initiated in 1998 with the formation of NCDOT's NPDES Permit Working Group and
Oversight Committee, which is recommended by the permit support documents. One of the first tasks assigned to the Working Group was the development of a new Stormwater Pollution
Prevention Plan (SPPP) template, which was accomplished via a Phase I pilot study of 10 NCDOT industrial facilities, meetings with NCDENR NPDES permit writers and Working Group members,
and approval by the Oversight Committee. Once the SPPP template was completed, Phase II was performed, which included site assessments of the remaining NCDOT industrial facilities in
1999. Site -specific SPPPs were developed for approximately 190 NCDOT industrial facilities and initial SPPP training workshops were provided to NCDOT Highway Divisions, the Ferry Division,
and Rail Division. Phase III involved developing annual training materials, initial development of an SPPP website, and general assistance with SPPP and BMP implementation. The NPDES
Permit Working Group has since morphed into HSP management and the function of the Oversight Committee is extended to NCDOT upper management, as needed.
Over the past three NPDES permit terms, NCDOT's HSP has greatly enhanced the IA Program through upgrades to the SPPP template, site -specific SPPP documents, SPPP website, training
materials, and other related program components. NCDOT continues to maintain and implement site -specific SPPPs at all NCDOT facilities with industrial activities covered by NCDOT's NPDES
Statewide Stormwater Discharge Permit (which includes approximately 200 facilities). NCDOT industrial facilities include county maintenance yards, equipment shops, bridge maintenance yards,
traffic services shops, roadside environmental shops, salt storage yards, material storage yards, truck stations, fuel stations, ferry terminals, a ferry maintenance facility, a rail maintenance facility,
an asphalt plant, and several other industrial -type facilities. The SPPP program includes semi-annual inspections of the facilities and of industrial stormwater discharge outfalls and ongoing
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HSP-IA - Vision Document
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implementation of best management practices (BMPs) to reduce potential impacts on stormwater from on -site activities such as salt and material stockpile management, vehicle and equipment
maintenance, and hazardous substance storage and handling. Additionally, the SPPPs include requirements to train facility personnel in preventative maintenance and spill response and
cleanup procedures.
In 2008, as part of NCDOT's ongoing IA Program, Spill Prevention Control and Countermeasure (SPCC) Plan requirements [40 Code of Federal Regulations (CFR) Part 1121 were integrated into
the SPPP process for certain NCDOT industrial facilities that meet or exceed 1,320 gallons of aggregate aboveground oil storage. NCDOT SPCC Plan requirements include regular inspections
and secondary containment for regulated oil containers, plan certifications, and additional spill response and notification procedures. Additionally in 2008, the HSP IA Program modified the
original SPPP training video created in 2000 to produce a separate spill prevention and response video module for NCDOT facility personnel. (Note: although the SPCC requirements are not
part of NCDOT's NPDES permit, the requirements and procedures for compliance are similar to those of the SPPP. Therefore, integration with the SPPP provides additional regulatory
compliance with minimal duplicity of efforts.)
NCDOT's IA SPPP Website is used by Division -level personnel and HSP Managers from Roadside Environmental Unit, Environmental Operations Section and Hydraulics Unit, and the AECOM
Program Manager to manage the implementation of SPPP and SPCC Plans for all NCDOT industrial facilities. The website tracks plan and BMP implementation, qualitative monitoring of
stormwater discharges, inspections, oil storage inventories, plan updates, training, plan certifications, and other task completion dates and deadlines. NCDOT has provided regular upgrades to
the SPPP website approximately every three to four years to further automate various processes and improve the sustainability of the IA Program.
NCDOT HSP Managers provide training assistance to the Divisions through ongoing training initiatives, such as annual regional training workshops, one-on-one training sessions, videos,
posters, signs, and other training materials and instructions provided to Division -level personnel each year. NCDOT SPPP Team Leaders provide training during monthly "bull pen" meetings,
watching annual refresher video modules entitled "Stormwater Pollution Prevention - Do Your Part at NCDOT" and "Spill Prevention and Response - Do Your Part at NCDOT', and through
"Stormwater Sam" posters and brochures posted at NCDOT facilities. NCDOT's Industrial Activities and Roadway Maintenance (IRMA) BMP Guidance Manual, issued in spring 2013 and updated
in subsequent years, provides additional training tools and pollution prevention guidance for SPPP Team Leaders and other NCDOT personnel. NCDOT HSP IA Managers also provide assistance
to Division personnel to fund certain SPPP site -specific BMPs at the facilities. HSP Managers also provide assistance to Divisions to fund certain structural stormwater control measures at some
facilities as part of the HSP Retrofit Program. When Division personnel develop creative solutions to stormwater quality concerns, HSP Managers take the opportunity to educate other
industrial facilities across the state. NCDOT HSP IA Managers are available to collaborate with other HSP Program Area Managers that may be affected by industrial processes performed at
NCDOT industrial facilities or along NCDOT roadways. As part of the ongoing evaluation of industrial processes and SPPP/SPCC Plan compliance, NCDOT HSP Managers periodically conduct
internal reviews of NCDOT's industrial facilities which may include in-depth internal inspections to evaluate SPPP/SPCC compliance and the effectiveness of facility BMPs, and to identify other
site -specific needs related to the IA Program and the NPDES permit as a whole.
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HSP-IA - Program Goals
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NCDOT > HSP > HSPAA > HSP-IA - Program Goals
HSP-IA IRMA BMP Guidance Manual
Program Goals
Permit -Term Goals — Industrial Activities
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This wiki documents the guiding principles of the HSP in general, explicit requirements in the NPDES permit for the IA Program, a strategy for making sure NCDOT is in compliance with permit
requirements, and the overall goals of the IA Program over the permit term.
HSP Guiding Principles:
The HSP is a Department -wide and statewide initiative to protect and enhance stormwater quality while fulfilling NCDOT's mission of providing and
supporting a safe, integrated transportation system. The HSP is guided by the following principles:
• Comply with NPDES Stormwater Permit requirements by managing and reducing stormwater pollutants from roadways and industrial areas.
• Design sustainable programs that can be effectively managed, implemented, and integrated into NCDOT.
• Develop solutions that improve program delivery, are proactive, form partnerships, have technical merit, and are fiscally responsible.
Permit Objectives:
Part ILD of NCDOT's NPDES Permit covers the Industrial Activities Program. The Permit objectives for the Industrial Activities Program are listed below.
Section D.1.a.i. Maintain and implement a Stormwater Pollution Prevention Plan (SPPP or Plan) for each facility with an industrial activity that is covered by
this permit.
Section D.1.a.ii. Develop and implement a Plan priorto operation of any new industrial facilities.
Section D.3.a.i. Evaluate the effectiveness of the industrial SPPP for each industrial facility.
Section D.3.a.ii. Perform required qualitative monitoring at stormwater discharge points or outfalls identified in the SPPPs or during supplemental
inspections as required in
Part II.D.2.i.
Part III.A.2 of NCDOT's NPDES Permit covers the Reporting and Record Keeping Requirements for SPPPs. The Permit objectives for the Reporting and Record
Keeping Requirements for SPPPs are
listed below.
Section A.2.a Implementation of the SPPP at each industrial facility shall include documentation of all monitoring, measurements, inspections, maintenance
activities and training provide
employees. Such documentation shall be kept on -site for a period of five years and be made available to DEMLR immediately upon request.
Section 6.1.b In the event that DEMLR determines that a SPPP does not meet the requirements of this permit, NCDOT shall submit a proposal and schedule
for modifying the SPPP. NCDOT shall also
certify that the SPPP has been modified in accordance with the submitted proposal.
Part 111.6.1 of NCDOT's NPDES Permit covers the Compliance Schedule for SPPPs. The Permit objectives for the Compliance Schedule for SPPPs are listed
below.
Section 6.1.a Existing Industrial Facilities: The required SPPP shall be updated on an annual basis.
Section 6.1.b Proposed/New Industrial Facilities: The SPPP shall be developed and implemented prior to the beginning of discharges from the operation of
the industrial activity and be updated
thereafter on an annual basis. Secondary containment shall be accomplished prior to the beginning of discharges from the operation of the
industrial activity.
Permit Management Measures:
Sections D.1.b. and D.3.b. of NCDOT's NPDES Permit are presented in the table below.
Management Measures
Measurable Goals
D.1.b. Maintain and
NCDOT shall maintain and implement a site specific Stormwater Pollution
implement a SPPP for each
Prevention Plan (SPPP) for each covered facility with an industrial activity.
covered industrial activity
For new activities or facilities, the SPPP shall be developed and
and related facility.
implemented prior to operation. New Activities and facilities shall be
identified in the annual report and include a brief description and location
information. SPPP requirements are listed [in Section D.2. of the Permit].
D.3.b. Perform visual
Qualitative monitoring shall be performed at each industrial stormwater
monitoring at each facility.
outfall twice per year, once in the spring (April —June) and once in the fall
(September —November). Qualitative monitoring requires an inspection
of each stormwater outfall or discharge point for the parameters listed [in
Section D.3.c. of the Permit]. Qualitative monitoring is for the purpose of
evaluating the effectiveness of the SPPP. No analytical tests are required.
NCDOT will pursue correction of stormwater quality where qualitative
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HSP-IA - Program Goals Page 2 of 3
monitoring indicates degradation of quality in comparison to previous
monitoring events.
Note: Part II.D.2 specifies the contents of the SPPP required in Part II.D.1.
Compliance Strategy:
The HSP Industrial Activities Program initiates the development of new SPPPs and tracks overall SPPP implementation for all NCDOT industrial facilities in
accordance with NCDOT's NPDES Permit management measure D.1.b., and as a part of the continuous process improvement approach NCDOT takes in
maintaining SPPPs at its industrial facilities. The HSP Industrial Activities Program has fully integrated the SPCC Plan requirements [40 CFR 112] into the
SPPPs and has continued to emphasize spill prevention and response practices at NCDOT industrial facilities. The HSP Industrial Activities Program
established an effective approach to providing new SPPP/SPCC Plans and SPPP/SPCC Plan updates for NCDOT industrial facilities by coordinating with
NCDOT Division level personnel, providing technical support and guidance, and regular training assistance.
This program maintains an efficient SPPP/SPCC website that is administered by NCDOT Information Technology (IT) personnel and used by industrial facility
and other Division -level personnel as well as HSP staff. The website is used to document and track SPPP implementation and other Industrial Activities
Program compliance activities such as semi-annual qualitative monitoring of stormwater discharges (in accordance with NCDOT NPDES Permit management
measure D.3.b.), facility inspections, and SPPP/SPCC Plan certifications.
HSP staff have also collaborated on the Industrial Activities Program Vision Document, which includes an overview of program goals, and other planning -
level information to help prioritize Industrial Activities Program projects and resources. For example, the HSP is continuing to develop new training sections
for NCDOT's IRMA BMP Guidance Manual for this new permit term.
The compliance approach will be to continue maintaining and implementing SPPPs/SPCC Plans for NCDOT industrial facilities, providing training and facility
review support for NCDOT division personnel, and integrating the results into other HSP program areas, as appropriate. As like the first 15+years of this
program area, HSP Industrial Activities Program Managers will follow the continuous process improvement approach as they look for opportunities to
improve overall compliance and efficiency in this program.
Program Permit -Term Goals:
• SPPP/SPCC Plan Updates — Continue to assist NCDOT Divisions with SPPP/SPCC Plan updates throughout each permit year for new facilities or as
significant changes occur to existing industrial facilities.
• SPPP/SPCC Training — Continue to provide training assistance to NCDOT Division personnel and expand training assistance to NCDOT Divisions as
needed to achieve HSP Internal Education Program goals. HSP IA Program trainers prioritize safety in all industrial operations and train Division
personnel to achieve these program goals with a focus on safety. Refer to the Internal Education section of this Vision Document for additional
details on training for the IA Program.
• SPPP/SPCC Website Maintenance — Continue to work with NCDOT IT staff and Division personnel to assist with maintaining and updating NCDOT's
SPPP/SPCC website and to add functionality to continuously improve work flow and program implementation for Division users (which includes
Division Points of Contact (POCs) and facility SPPP Team Leaders (TLs). The SPPP/SPCC website is functional, but also requires periodic assistance
from NCDOT IT staff to address low-grade maintenance needs, as well as periodic website upgrades (typically every three to four years).
• Update SPPP/SPCC Plan Integrated Template Document— Continue to update the SPPP/SPCC Plan Integrated Template Document, including
Appendices, Inspection Forms, or Figures as needed. Revisions are based on:
o Communication meetings or recommended and approved protocol changes from NCDOT REU, Environmental Operations Section or Hydraulics
Unit Program Managers;
o New or revised regulations (i.e., NPDES permit requirements or amendments to SPCC regulations), or new BMP guidance from DEQthat
becomes available during the permit term;
o Additional BMP guidance to support additional program areas (e.g., the Jordan Lake Green Program for industrial facilities located within the
Jordan Lake Watershed);
o New creative SPPP BMPs developed by NCDOT or other outside entity, or
o Construction of new facilities or changes to existing facilities.
• IA Program Management — Continue to support NCDOT HSP Program Managers and Division personnel for related industrial activities as they pertain
to NCDOT's Statewide NPDES Permit or stormwater pollution prevention. This includes:
o Evaluating the performance of current and proposed NCDOT practices in terms of reduced environmental impacts or evaluating SPPP/SPCC Plan
implementation at NCDOT industrial facilities. This is typically accomplished by IA Program Managers:
• Performing SPPP/SPCC Plan compliance reviews (or mock inspections/ audits) of NCDOT industrial facilities;
• Assisting Divisions with DEQ inspections (e.g., follow-ups or general guidance, recommendations, and/or SPPP/SPCC Plan updates);
• Identifying Stormwater Control Measures (SCMs) located on industrial facilities and providing SCM Inspection and Maintenance
guidance to the applicable facility personnel;
• Developing or updating BMP prioritization schemes for NCDOT industrial facilities;
• Assisting with providing guidance on NCDOT wash pad connections and OWS replacements, as well as related connections to municipal
sanitary sewer systems;
• Conducting evaluations of NCDOT industrial operations and providing recommendations to minimize stormwater pollution from the
industrial activities (i.e., Bridge Cleaning Observation Report from the Division 9 April 2011 Bridge Cleaning Project).
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HSP-IA - Program Goals
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o Continually evaluating opportunities for program improvement as part of NCDOT's continuous process improvement approach, identifying
measures that support environmental stewardship with greater efficiency (less maintenance needs), sustainability (less manpower, funding
requirements), and innovativeness (new technologies, methods); and
o Disseminating results of improvements in stormwater BMP technologies internally and externally to educate Division level personnel
responsible for managing or performing industrial operations, and conversely disseminating results of creative BMPs or cost effective
approaches to implementing SPPPs created by individual SPPP Team Leaders/ Team Members back to other NCDOT Divisions and HSP IA
Program Managers.
Program Assessment:
Ongoing development and implementation of the IA Program is assessed through several mechanisms to evaluate its compliance with the requirements and
intent of NCDOT's permit. These mechanisms include:
• Review meeting with NCDEQ staff, generally held annually.
• Update and review of this Vision Document to review previous work and plan for future program needs, generally performed once every 12 months.
• Review and documentation of the current year's efforts through the writing of the Annual Report, developed annually.
• Review and assessment by a third party entity (usually another consultant), performed as needed.
Program Permit -Term Goals:
• Continue to utilize IA Vision Document review and other IA Program meetings as annual process review and improvement periods for the IA Program:
For example, an internal IA Program review conducted in 2013 after the completion of internal site reviews at NCDOT facilities identified the
need to provide specialized training for Equipment Unit personnel, so NCDOT HSP staff developed and provided specific training for Equipment
Shop personnel in spring 2014.
Similarly, NCDOT HSP staff developed and provided specific training for Roadside Environmental staff in spring 2015.
Assist Division personnel in maintaining compliance with IA program permit goals.
• Continue improvements to IA program and provide support to other program areas such as Retrofits Program, I&M Program, Research Program, and
TMDL Program.
Proposed Projects
Proposed Projects should be designed to meet Program Area Permit -Term Goals. Each program is different. Some program areas allow very specific projects
to be identified for the life of the permit while projects for other program areas can only be clearly stated and identified for shorter periods of time. The
Proposed Project list includes SMART Projects," which meet the criteria of being Specific, Measurable, Achievable, Realistic, and Timely. Projects that do not
meet these criteria are listed in the Proposed Projects list as 'Project Ideas."
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HSP-IA - Communication Plan Page 1 of 2
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Communication Plan — Industrial Activities Program
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Each program area is led by technical staff in the business unit having primary (P) responsibility and authority to implement the requirements, with support (S) from other business units.
These roles were established in the HSP Business Plan as listed below.
Permit Section Description I H_YD REU DIV I RAL I FRY FMU DMV TPK
Section D Industrial Facilities _
D.1 Develop, Maintain, and Implement P P P S S
Stormwater Pollution Prevention Plans
D.2 Stormwater Pollution Prevention Plan P
Requirements for Industrial Activities _1 1
D.3 Qualitative Monitoring _ P L P I P
P = Primary Lead, S = Support, HYD = Hydraulics Unit, FRY= Ferry Division, REU = Roadside Environmental, FMU = Facilities Management Unit, DIV = 14 Divisions, DMV = Division of Motor Vehicles, RAL= Rail Division, TPK = NC
Turnpike Authority
Stakeholder Communications
Communications with NCDOT Upper Management:
• Communication with NCDOT upper management is performed primarily on an as -needed basis. Communication with NCDOT upper management will be made at
the discretion of the NCDOT HSP Program Area Manager and NCDOT Project Manager. SPPP/SPCC Plan implementation status information for all NCDOT industrial
facilities is available on the SPPP/SPCC Plan website to use in reports to upper management.
• This program will be included in the NPDES Permit Annual Report, which is provided to NCDOT management for review and approval, prior to being submitted to
NCDEQ.
• Overview information and status for individual projects will be maintained on the HSP IA SharePoint site homepage.
• Topics of discussion may include overall SPPP implementation, training needs, results of NCDEQ inspections at NCDOT industrial facilities, BMP prioritization and
funding, and various industrial activity related projects or research studies.
Communications with NCDOT Staff and Contractors:
• AECOM's HSP Program Manager or IA Program Manager will communicate on a regular basis with NCDOT's HSP IA Project Managers or staff (i.e., at least monthly)
concerning the status of IA Program task orders, schedules, upcoming deadlines, and other initiatives.
• Any problems that are identified with SPPP/SPCC website (including program bugs, data entry errors, or other system problems, as well as proposed changes to
SPPP/SPCC website) are documented in the SPPP Tracking Log (an Excel spreadsheet) found on the NCDOT HSP IA Program SharePoint site. Note: NCDOT IT Web
Services also logs SPPP system bugs using their own internal system.
• AECOM and NCDOT IA Program Managers will help communicate ongoing issues related to the IA Program on a regular basis to other NCDOT HSP members as
appropriate. and NCDOT IA Program Managers will help communicate ongoing issues related to the IA Program on a regular basis to other NCDOT HSP members as
appropriate.
• All parties are allowed to communicate directly with other participants in the IA Program area. However, it is recommended that NCDOT staff make the first
contact with other NCDOT forces (i.e., Division staff) to introduce other participants (i.e., AECOM or specialty consultants) and clearly identify that these individuals
may be in direct contact with NCDOT forces (Exception: AECOM or specialty consultants are encouraged to draw from the expertise of other NCDOT forces with
whom they have a good working relationship when insight from such staff is needed or may benefit the Industrial Activities Program).
• Communication about the IA Program will also occur at various internal NCDOT conferences and workshops, potentially including REU's Annual Vegetation
Management Conference and NCDOT's Annual Maintenance Conference.
• Discussion with NCDOT staff outside of the HSP will generally involve coordination of SPPP/SPCC updates with Division personnel (including Division POCs and
facility Team Leaders), acquisition of data, or scheduling visits or upcoming training sessions.
• Coordinate public education components with the Offices of Communication and Beautification, if appropriate.
• Discussion with other contractors on issues related to the Industrial Activities Program will generally involve coordination of industrial activities performed by
contractors along NCDOT roadways or at NCDOT non -road facilities.
• Existing NCDOT communication strategies or technologies will be used to effectively communicate appropriate aspects of the IA Program with NCDOT staff and
contractors.
Communications with NCDEQ:
• Members of the IA Program team will communicate with the NCDEQ permit writer on an as needed basis, with a proposed minimum of once a year, to review SPPP
implementation, recent industrial activities projects, and ongoing initiatives. Communication will be facilitated by the NCDOT HSP Program Manager, except where
expressly delegated to the AECOM HSP Program Manager, IA Program Manager, or others.
• Progress will be communicated to NCDEQ in annual reports per the NPDES permit requirements.
Communications with FHWA, other State DOTS and other Transportation Bodies:
• Seek opportunities to collaborate with other State Highway practitioners on IA lessons learned or useful technologies (e.g., winter weather maintenance, liquid
asphalt or salt brine management, bridge deck cleaning, cutting -edge industrial processes or creative BMP implementation approaches to industrial activities).
• Follow national efforts by FHWA and NCHRP, and communicate IA Program successes with FHWA and NCHRP as appropriate to promote NCDOT HSP.
• Initial communication with outside entities shall be initiated by the NCDOT HSP Program Manager, except where expressly delegated to the AECOM HSP Program
Manager or HSP IA Program Manager.
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Communications with the Public:
• Ongoing direct communication with the public about NCDOT industrial activities is not required by the NPDES permit under the IA Program Area; however, the IA
Program supports external education initiatives.
• Examples of topics that might be discussed to support the External Education Program by providing education to the Public include:
o Stormwater BMPs being implemented at NCDOT industrial facilities to minimize stormwater pollution,
o How to identify and report illicit discharges and illegal dumping,
o Use of a rain garden or rain barrels used at NCDOT industrial facilities, or
o Other spill prevention and response practices employed by NCDOT personnel (e.g., NCDOT uses dry absorbents to clean up fuel spills).
Communication may occur through the following potential mechanisms (ideas):
o Educational displays/markers, signs, or posters placed at NCDOT industrial facilities in specific locations open to the Public,
o NCDOT's public website (e.g., show IA Program creative SPPP BMPs or success story features on the NCDOT Story Ideas webpage or NCDOT Now, a weekly
video magazine on NCDOT's website),
o Public hearings, and
o Public events/Festivals (e.g., displays or brochures handed out at North Carolina State Fair).
• Communication with the Public is appropriate at certain NCDOT industrial facilities which are more open to the Public (such as NCDOT Ferry Terminals).
• Existing NCDOT communication strategies or technologies will be used to effectively communicate appropriate aspects of the Industrial Activities Program with the
Public.
Annual Report:
Projects and tasks performed under this program will be documented in the NPDES Permit Annual Report. The IA Program Manager will gather SPPP website statistics
and related industrial facility photographs and summary text related to the IA permit year and provide this information to the HSP Annual Report preparation team. The
HSP Program Managers and NCDOT IA Program Manager will review the Annual Report IA section for each permit term.
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Education Approaches — Industrial Activities Program
Internal Education
This section will include a description of internal education efforts and requirements, including training, and should align with the Internal Education Plan.
Internal training for select IA Program elements will be given at the discretion of the NCDOT HSP Program Area Manager.
As required by the NPDES Permit, NCDOT industrial facility employees that have the potential to impact stormwater runoff quality from NCDOT industrial
facilities receive annual stormwater pollution prevention training. Videos, posters, brochures, signs, briefings, and annual training workshops are some of
the approaches the HSP Industrial Activities Program uses to educate NCDOT facility personnel on stormwater pollution prevention awareness. This training
also includes good housekeeping, preventative maintenance, and spill prevention and response practices. Additionally, NCDOT facility personnel are trained
on how to recognize and report illicit discharges and illegal dumping activities.
Part ILD and Part ILE of the NPDES Permit require employee training for appropriate NCDOT staff. This internal training must also be included in the Internal
Education and Involvement Plan per Part II.E.1.b.(e) of the Permit.
Existing IA Program training activities/approaches include:
• SPPP/SPCC Plan Implementation Training Workshops
Who: Attendees typically include NCDOT facility SPPP Team Leaders, team members, or other interested Division staff (often includes
both new facility staff and those seeking refresher training).
Where: Regional/Division-wide sessions or individual (one-on-one) sessions.
When: Workshops are typically offered to NCDOT Divisions each spring (although the number of workshops offered each year has
varied throughout NCDOT's first three permit terms).
Agenda: Workshop agendas have varied over the years. The standard six -hour SPPP/SPCC Plan Implementation Training Course used
from 2003 to 2011 was modified in the Spring of 2012 and split into two separate courses, Level 1 and Level 2:
■ Level I (Introductory Review of SPPP/SPCC Plan Requirements/ Implementation), and
■ Level II (Advanced SPPP/SPCC Plan Update and Review).
■ 2013 Workshops followed this same Level 1 and Level 2 model.
Unit Specific Training: NCDOT IA Program also provides unit -focused or specialized training in morning sessions along with advanced
training in afternoon sessions. NCDOT IA Program Managers plan to continue to mix in unit -specific training along with general
awareness training each year along with the advanced training for SPPP Team Leaders since this approach has proven to be very
effective and feedback has been very positive.
■ Spring 2014 Workshops: In the morning, a new course SPPP/SPCC Plan Implementation Training for Equipment Shop Staff was
provided with new presentations, handouts, posters, and updated procedures specifically designed for Equipment Shop staff.
This course was developed to address issues identified during internal facility reviews performed by IA Program Managers in
2013. The 2014 afternoon session provided advanced training and new updates for SPPP Team Leaders.
■ Spring 2015 Workshops: In the morning, a new course SPPP/SPCC Plan Implementation Training for Roadside Environmental
Staff was provided with new presentations, handouts, posters, and updated procedures specifically designed for Roadside
Environmental staff. This course was developed to address issues identified during internal facility reviews performed by IA
Program Managers in recent years along and the Third Party Review of NCDOT's NPDES Permit performed in 2014. The 2015
afternoon session provided advanced training and new updates for SPPP Team Leaders.
■ Spring 2016 Workshops: NCDOT IA Program Managers will continue to offer new and improved training courses/materials each
year to provide NCDOT Division staff including Team Leaders with effective training and important updates.
■ Spring 2017 Workshops: NCDOT IA Program Managers will continue to offer new and improved training courses/materials each
year to provide NCDOT Division staff including Team Leaders with effective training and important updates.
• SPPP/ SPCC Training videos used for annual refresher training:
SPPP Video Module "stormwater Pollution Prevention — Do Your Part at NCD07 which is used to provide initial training to applicable
newly -hired NCDOT maintenance workers, for annual refresher training to individual NCDOT maintenance workers, or in group
training sessions as part of SPPP/SPCC training requirements; and
SPCC Plan Video Module "Spill Prevention and Response — Do Your Part at NCDOT", which is also used for initial or annual refresher
training for NCDOT maintenance staff.
NCDOT IA Program Managers continue to look for opportunities to develop new video modules to help SPPP Team Leaders and
Division staff improve their stormwater pollution prevention practices.
• NCDOT IRMA BMP Guidance Manual training tool for NCDOT Industrial Facility SPPP Team Leaders to use during monthly morning
briefings. NCDOT IA Program Managers typically provide updated IRMA sections or chapters to NCDOT SPPP Team Leaders annually
during the spring workshops.
• Educational posters displayed at NCDOT industrial facilities, which typically demonstrate good housekeeping or stormwater pollution
prevention awareness message (e.g., new Stormwater Sam 11x17 laminated posters designed for NCDOT maintenance yard bull pens/crew
rooms):
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HSP-IA - Education Approaches
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2010 Poster "What's Coming Outta Your Pipe?" distributed internally;
2011 Poster: "Before You Hose, Know Where It Goes" distributed to Divisions during spring 2011 Workshops; and
2012 Poster: "Talk is Cheap! Help Stop Illegal Dumping. If you See it, Report it!" distributed to Divisions during spring 2012
Workshops.
2013 Poser: "You ... Are the Solution to Stormwater Pollution" distributed to Divisions during spring 2013 Workshops.
2014 Poster: "Remember... You Can Prevent Stormwater Pollution" distributed during spring 2014 Workshops to Equipment Shop
Supervisors for posting in Equipment Shops.
2015 Poster: "Inspect to Protect ... Stormwater!" distributed during spring 2015 Workshops to Roadside Environmental staff and SPPP
Team Leaders to post in Roadside Environmental Shops and other Maintenance Yard Crew Rooms.
2016 Poster: "Secure Your Load for Safer Roads and Cleaner Stormwater" distributed during spring 2016 Workshops to Roadside
Environmental staff and SPPP Team Leaders to post in Roadside Environmental Shops and other Maintenance Yard Crew Rooms.
2017 - 2018 Posters: "Drive Away Distractions When Refueling!", "Don't Get Sidetracked While Refueling!", and "Oh Buoy! Don't Sail
Somewhere Else While Refueling..." will be distributed during 2018 Workshops and individual sessions to Roadside Environmental
staff and SPPP Team Leaders to post in Division Shops and other Maintenance Crew Rooms.
• Periodic briefings by Division -level staff (e.g., monthly bull pen environmental/safety meetings that often includes a stormwater related
topic).
• Periodic briefings to NCDOT employees at NCDOT management meetings and annual/ statewide conferences, including, but not limited to,
Construction conferences, Maintenance conferences, and Vegetation Management conferences.
• Other NCDOT internal training courses related to stormwater pollution prevention (e.g., Snow and Ice Management, Vegetation
Management).
• Other NCDOT internal conferences where stormwater pollution prevention awareness topics are discussed.
• Educational flyers provided to NCDOT industrial facilities (e.g., "Salt Works", "Good Housekeeping", "Illicit Discharge: Know What to Do").
• Planned training materials under development (e.g., new handouts and poster for each upcoming SPPP/SPCC Plan Implementation
Training Workshops and along with updated sections or chapters to NCDOT's IRMA BMP Guidance Manual training tool for NCDOT
Industrial Facility SPPP Team Leaders) and new training videos for SPPP Team Leaders.
New signs for NCDOT Fuel Stations to provide guidance to non-NCDOT state employees as well as NCDOT staff that refuel
vehicles/equipment at NCDOT Fuel Stations.
Note: these training materials can be used by NCDOT facility staff to train other non-NCDOT individuals such as contractors or prison
inmate laborers that may perform work on NCDOT industrial facilities, as applicable.
• Coordinate with appropriate HSP Program Managers on the "Stormwater 101" curriculum/tool planned for development for NCDOT staff
and contractors to properly incorporate an appropriate level of Industrial Activities Program guidance into the general stormwater
awareness level training curriculum/tool.
Additional Internal Education ideas include:
Provide newly developed training materials including new posters and handouts during annual training workshops each year, as
appropriate.
Provide new chapters for inclusion in NCDOT's IRMA BMP Guidance Manual training tool and provide to facility SPPP Team Leaders to use
during monthly morning briefings. In addition, IRMA BMP Guidance Manual chapters can be used to train other non-NCDOT individuals
such as contractors or prison inmate laborers that may perform work on NCDOT industrial facilities, as applicable.
Periodically evaluate other types of training materials or approaches that have not been used before (e.g., standard signage to post at
facilities, refrigerator magnets, calendars, vehicle bumper stickers, vehicle air fresheners, annual contests, games, quizzes, BMPs of the
month, facility awards).
Provide newly developed videos related to the IA Program to support annual training, as appropriate.
External Education
There are no explicit requirements in the permit regarding external education for the IA Program. However, the following are offered as ideas for external
education opportunities within the IA Program to assist the other program areas with ideas for cross -training, as well as to assist the External Education
Program Manager, who is responsible for ongoing educational opportunities within the HSP. Refer to the Communications Plan — IA Program,
Communication with the Public section for examples of external education approaches related to the IA Program.
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HSP-IA - Program Area Integration
Page 1 of 2
NCDOT > HSP > HSP-IA > HSP-IA - Program Area Integration
HSP-IA IRMA BMP Guidance Manual Industrial Activities Training Site Div 9 Bridge Cleaning
Program Area Integration
Integration with Other Program Areas — Industrial Activities Program
Access: Owners and Members
Michelle Mayfield - 0
EDIT LINKS Search this site
Introduction: This wiki describes the processes by which the Industrial Activities Program will integrate with other HSP program areas and NCDOT initiatives.
This section should be a description and not just a list of projects —it can reference projects in the Proposed Projects List. It should not repeat too much
information that is already presented in the Intro and Compliance Strategy sections.
The Industrial Activities Program coordinates extensively with several other programs:
Stormwater System Inventory and Prioritization Program
On a regular basis (at least annually), the IA Program will provide a list of outfall locations to the Stormwater System Inventory and Prioritization (SSIP)
Program for inclusion in the Outfall Inventory.
Construction
• Industrial Activities Program Managers will coordinate with Construction Program Managers to develop training materials and guidance as appropriate
to address the management of construction activities that occur at NCDOT industrial facilities, such as incorporation of managing concrete washout by
using structural and non-structural BMPs to prevent stormwater pollution. The primary methods this will be accomplished is through NCDOT's
SPPP/SPCC Plan document and NCDOT's IRMA BMP Guidance Manual. Topics included in the IRMA manual that provide additional training materials
for managing and controlling wastes that may cause adverse impacts to water quality at construction activities located on NCDOT industrial facilities
include: Outdoor Raw Materials Storage and Stockpiling, Waste Handling and Disposal, and Stormwater Management.
Illicit Discharge Detection and Elimination Program (IDDEP)
• Industrial Activities Program Managers will coordinate with NCDOT HSP IDDEP Coordinator to include updated IDDEP information into annual SPPP
training workshops provided for NCDOT facility personnel.
• Industrial Activities Program Managers will continue to work with NCDOT facility staff on performing non-stormwater discharge evaluations at NCDOT
industrial facilities to identifying illicit discharges to the facility's storm system.
Inspection and Maintenance (I&M) Program
• There are NCDOT industrial facilities that have SCMS on their grounds. The HSP will work to help identify SCMS located on NCDOT industrial facilities
so they can be incorporated into NCDOT's Stormwater Control Management System (SCMS). The HSP will work to communicate the inspection and
maintenance requirements, as well as the points of contact responsible for these SCMS. Improved communication about program area protocols will
promote the best management of NCDOT assets.
Internal Education and External Education
• Industrial Activities Program Managers will work jointly with Internal and External Education Program teams to properly educate internal NCDOT
facility personnel, contractors, or prison inmate laborers that access NCDOT industrial facilities on stormwater pollution prevention awareness, which
includes good housekeeping, preventative maintenance, and spill prevention and response.
• Industrial Activities Program Managers will work with NCDOT's Public and Internal Education Program staff to make sure that internal Industrial
Activities training is included in the Internal Education and Involvement Plan and to maximize other training potential of this important program both
internally and publicly.
Retrofits
• Industrial Activities Program Managers will work with HSP Retrofits Program Managers to identify any retrofit opportunities at NCDOT industrial
facilities.
• During site reviews performed at NCDOT industrial facilities, Industrial Activities Program Managers will evaluate any on -site retrofit projects or other
SCMS and will report back to HSP Retrofits Program Managers on the effectiveness of the SCMS, any other ongoing operational issues, and potential
benefits to other facilities.
• As design changes occur with SCMS located on NCDOT industrial facilities, the Industrial Activities Program will work with NCDOT personnel that install,
inspect, or maintain SCMS at industrial facilities to inform them of these changes.
Research Program
• Industrial Activities Program Managers will work with NCDOT's Research Program Managers and Division personnel to identify appropriate research
project opportunities at NCDOT's industrial facilities or associated with NCDOT roadway maintenance activities along NCDOT Right -of -Way.
• Industrial Activities Program Managers will coordinate with research activities if they may impact related NCDOT industrial activities.
• Industrial Activities Program Managers will evaluate new research studies or results that are associated with NCDOT industrial operations (i.e.,
roadway or bridge maintenance activities) to determine if additional training should be incorporated into annual training workshops, briefings, or other
educational materials for NCDOT industrial facilities.
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HSP-IA - Program Area Integration
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Total Maximum Daily Load (TMDL)
• Industrial Activities Program Managers will work with TMDL Program Managers to identify and facilitate any additional training that may be needed at
any NCDOT industrial facilities or other non -road facilities that may be located within other TMDL impacted watersheds, as needed.
• Incorporate TMDL information into SPPPs as applicable.
Post -Construction Stormwater Program/Guided Reduction of Excess Environmental Nutrients (GREEN) Program
• The IA Program will support the Post -Construction Stormwater Program (PCSP) team to update PCSP guidance applicable to non -road facilities.
• NCDOT industrial facilities located within specific watersheds (e.g., Jordan Lake, Falls Lake Watersheds) will need to comply with new rules (e.g., Jordan
Lake Rules). HSP staff will work to communicate these new requirements to NCDOT Divisions located within the specific watersheds. New nutrient
management education that is developed by HSP or required (i.e., certification by NCDENR) as part of the GREEN Program will be incorporated into the
Industrial Activities Program, as appropriate (i.e., additional BMP guidance on nutrient management may be added to Section 3 of the SPPP/SPCC
Integrated Template or other portions of the IRMA BMP Guidance Manual).
• Industrial Activities Program Managers will work with TMDL/GREEN Program Managers to identify and facilitate any additional training that may be
needed at any NCDOT industrial facilities or other non -road facilities that may be located within other TMDL impacted watersheds, as needed.
Information Technology (IT) Management
• Various information technologies are used to implement components of the IA Program as well as to effectively communicate appropriate aspects of
the IA Program to NCDOT staff, contractors, and the Public. IA Program Managers coordinate with HSP Program Managers and NCDOT IT personnel on
the use of these technologies, which include:
o SPPP/SPCC website maintenance and upgrades
o Geographic Information System data for SPPP/SPCC Plan preparation
o Database software associated with BMP prioritization
o HSP SharePoint site
o Environmental Sensitivity Maps
o Multi -Sensor Precipitation Estimates
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HSP-IA - Resources Needed Page 1 of 1
NCDOT > HSP > HSP-IA > HSP-lA - Resources Needed Michelle Mayfield - 0
HSP-IA IRMA BMP Guidance Manual Industrial Activities Training Site Div 9 Bridge Cleaning EDIT LINKS I Search this site
s Resources Needed
Resources Needed - Industrial Activities Program
Introduction: This wiki documents the skills, equipment/materials, and other needs for the program areas that are not currently available. Where you
envision a particular task will require assets beyond those currently incorporated into the HSP, please list them here. For example, an engineer with
experience in the design and installation of open graded friction course (OGFC) maybe needed to initiate or complete a task. Where possible, an estimated
need date and a reference to a proposed or approved project should be included.
Individuals/skills needed
• No other individuals or additional skills are needed at this time.
Equipment/materials needed (new topics/concerns)
• No equipment or materials are needed at this time.
Other
• No other needs identified at this time.
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Fiscal
Year Status Project Name Project Type
Updateof the Industrial
Problem Statement
Project Scope
Suggested Suggested
Start Date End Date
Outfalls data, maps, and ESM
Mapping the XY coordinates using a flat file from the NCDOT IT Group using GIS software. The
Fall 2018 & Spring 2019
update will be subject to QA/QC protocol, which includes validating the general location of the
2019 Proposed (Biannual) SMART
This is required by the NPDES permit.
assets and confirming the correct county. Tasks will include updating IDDEP and IA locations.
7/1/2018 6/30/2019
Should EPA audit the program, quick and easy access to
compliance records are necessary. An inventory where
DOTTMs, with help as needed from AECOM, will identify the location of compliance -related
IA Compliance Document SMART Top
files are located will be helpful to find information fast,
documents and fill in a document inventory tracking list, expected to be hosted on SP. The list
2019 Proposed Inventory 2019 Priority
especially if the task managers are unavailable.
should be updated as new documents are generated, or no less than once a year
7/1/2018 6/30/2019
Potential changes to NPDES Permit requirements, SPCC
Evaluate SPPP/SPCC Template changes and coordinate these with NCDOT IT when coordinating
regulations, NCDEQ guidance, or NCDOT's approach to
next SPPP/SPCC Plan website upgrade project. This requires coordination with NCDOT IT as the
SPPP/SPCC Plan implementation necessitate periodic
template is incorporated into NCDOT's SPPP/SPCC website. Major changes to the SPPP/SPCC Plan
SPPP/SPCC Plan Template
updates of the SPPP/SPCC Integrated Template
Template should occur simultaneously with any website upgrade. Minor SPPP/SPCC Template
2019 Proposed Document Update SMART
Document.
modifications can be done anytime throughout the permit year.
7/1/2018 1/31/2019
HSP will coordinate SPPP/SPCC Plan updates, which typically includes site visits, SPPP Site Plan and
text updates, and BMP recommendations. The updates will also involve evaluating BMP
effectiveness, providing guidance on SPPP and BMP implementation strategies, inspecting BMPs,
updating SPPP website, and providing general assistance to SPPP Team Leaders. Updates will also
SMART Top
Regular changes occur at NCDOT industrial facilities each
include compliance reviews of industrial facilities and provision of BMP recommendations. Effort
2019 In Progress SPPP/SPCC Updates FY 2019 Priority
year necessitating routine updates of SPPP/SPCC Plans.
includes site reviews.
7/1/2018 6/30/2019
Due to constant changes at NCDOT facilities and NCDOT
facility personnel, it is important that annual live
Provide SPPP/SPCC Plan Implementation Training Workshops (Regional or Division -wide Training,
training is available for NCDOT Division personnel.
as well as individual training as needed); [Level I General Awareness, and Level II Advanced
Additionally, annual or periodical NCDOT management
Training]. AECOM will coordinate with NCDOT HSP IA Managers to schedule and perform any
SPPP/SPCC Training SMART Top
meetings or conferences should be attended to present
additional training seminars for NCDOT staff (i.e., at NCDOT Construction, Maintenance, or other
2019 In Progress Assistance Priority
NCDOT IA program successes.
conferences).
7/1/2018 6/30/2019
HSP IA Managers need to periodically evaluate IA
training program needs to address changes in the
HSP will coordinate Annual IA Educational Materials Meeting(s) to review planned training
Annual IA Educational
program and to effectively target more immediate
materials and discuss topics to make sure HSP is diversifying topics across different IA educational
2019 Approved Materials Meeting(s) FY 2019 SMART
needs.
materials (e.g., posters, flyers, signs, IRMA).
7/1/2018 6/30/2019
Develop 3 poster concepts and move forward with one. Create annual poster for NCDOT
Industrial Activity Training Workshops planned for NCDOT employees with stormwater messages
on an annual refresh schedule. Standard laminated 11X17 Poster with creative message, cartoon
SMART Top
2019 Poster needs to be developed to provide
style, and NCDOT HSP's Stormwater Sam character will be utilized in poster. Project includes
2019 Approved Annual Poster- FY2019 Priority
stormwater awareness training to NCDOT staff.
production of —200 copies.
10/15/2018 3/1/2019
Vision Documents are intended to be "living
Review/Revise Vision SMART Top
documents" and should be updated to reflect changes
2019 Approved Document FY2020 - IA Priority
in priorities.
Review 2019 Vision Document and update to address program needs for FY 2020.
3/1/2019 5/15/2019