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Home My WebLink About21_NCS000250_HSP_Internal-Education-Plan_2019_UpdateHighway tormw ter Internal Education Plan 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 September 2019 NCDOT NPDES Permit NCS000250 This Page Intentionally Left Blank L':- Highway Stor111water Internal Education Plan Table of Contents ExecutiveSummary.................................................................................................................................1 1.0 Introduction to NCDOT HSP Internal Education Program..........................................................1-1 1.1 Internal Education Program Goals and Objectives........................................................1-1 1.2 Types of Training Included in IE Program.....................................................................1-2 1.3 NPDES Permit Training and Reporting Requirements...................................................1-3 1.4 Internal Education Plan Maintenance..........................................................................1-5 2.0 Implementation of Internal Education Program Objectives......................................................2-1 2.1 Objective 1: Implement a program to train NCDOT staff and contractors about the importance of stormwater quality............................................................................... 2-1 2.2 Objective 2: Incorporate training topics such as spill control, chemical application, and identification of illicit discharges and illegal dumping into training program .......... 2-1 2.3 Objective 3: Disseminate the results of NCDOT-sponsored and other transportation -related research to NCDOT staff and contractors in a timely and context -related manner...............................................................................................2-3 2.4 Objective 4: Develop training, guidance, and other outreach materials that are user-friendly, that relate to the user's job duties, and that are tailored to the targetedaudience . ...................................................................................................... 2-4 2.5 Objective 5: Integrate the development and dissemination of training materials into the development of tools, manuals, and practices created across the HSP........... 2-4 2.6 Objective 6: Make training, guidance, and other outreach materials readily available and accessible to NCDOT staff, contractors, and the general public ............... 2-6 2.7 Objective 7: Document the HSP's educational practices and successes ........................ 2-7 3.0 NCDOT NPDES Permit Priorities............................................................................................... 3-1 3.1 Erosion Control Training for Construction Workers ...................................................... 3-1 3.2 Pollution Prevention Training for Maintenance Workers ............................................. 3-1 3.3 Pollution Prevention Training for NCDOT Staff............................................................. 3-1 3.4 PCSP and BMP Implementation Training......................................................................3-1 3.5 Highway Stormwater Website for Business Partners .................................................... 3-2 3.6 Nutrient Management.................................................................................................3-3 4.0 Sustaining the Internal Education Program..............................................................................4-1 List of Tables Table 1-1. Summary of NCDOT's NPDES Permit Training and Reporting Requirements Table 2-1. Examples of Ongoing Training.................................................................... 1-4 2-1 NCDOT NPDES Permit NCS000250 iii September 2019 L' Highway Stormwater Internal Education Plan List of Acronyms AASHTO American Association of State Highway and Transportation Officials BAE Biological and Agricultural Engineering BMP Best Management Practice CFR Code of Federal Regulations Cop Community of Practice DEO Division Environmental Officer DOT Department of Transportation DREE Division Roadside Environmental Engineer EPA Environmental Protection Agency ESM Environmental Sensitivity Map FHWA Federal Highway Administration FTA Federal Transportation Administration GREEN Guided Reduction of Excess Environmental Nutrients HSP Highway Stormwater Program IDDEP Illicit Discharge Detection and Elimination Program I&M Inspection and Maintenance IE Internal Education IRMA Industrial and Roadway Maintenance Activities JLSLAT Jordan/Falls Lake Stormwater Load Accounting Tool LID Low Impact Development LMS Learning Management System MPE Multi -Sensor Precipitation Estimates NCAC North Carolina Administrative Code NCDA&CS North Carolina Department of Agriculture and Conservation Service NCDEQ North Carolina Department of Environmental Quality NCDOT North Carolina Department of Transportation NCSU North Carolina State University NPDES National Pollutant Discharge Elimination System PCSP Post -Construction Stormwater Program SCM Stormwater Control Measure SCMS Stormwater Control Management System SECREF Soil and Erosion Control Research and Education Facility SMP Stormwater Management Plan SPCC Spill Prevention, Control, and Countermeasure SPPP Stormwater Pollution Prevention Plan SOIPP Stormwater Outfall Inventory and Prioritization Program TMDL Total Maximum Daily Load UNCC University of North Carolina Charlotte USDA United States Department of Agriculture USGS United States Geological Survey NCDOT NPDES Permit NCS000250 iv September 2019 _c - Highway Stormwater Internal Education Plan Executive Summary The Internal Education (IE) Program of NCDOT's Highway Stormwater Program (HSP) establishes and supports the framework of greater environmental awareness and continuous improvement for NCDOT's employees and contractors. NCDOT implemented the IE Program during Term 1 of its National Pollutant Discharge Elimination System (NPDES) permit, issued in 1998. Since then, NCDOT has continuously maintained the IE Program through dedication of manpower and funding for educational initiatives, and through planning for staff and contractor education on topics associated with stormwater quality. This IE Plan provides the framework within which NCDOT implements the IE Program. The IE Plan is structured around the IE Program objectives, which are listed below: 1. Implement a program to train NCDOT staff and contractors about the importance of stormwater quality. 2. Incorporate topics such as spill control, chemical application, and identification of illicit discharges and illegal dumping into the training program. 3. Disseminate the results of NCDOT-sponsored and other transportation -related research to NCDOT staff and contractors in a timely and context -related manner. 4. Develop training, guidance, and other outreach materials that are user-friendly, that relate to the user's job duties, and that are tailored to the targeted audience. 5. Integrate the development and dissemination of training materials into the development of tools, manuals, and practices created across the HSP. 6. Make training guidance and other outreach materials readily available and accessible to NCDOT staff, contractors, and the general public. 7. Document the HSP's educational practices and successes. NCDOT intends to continue the educational efforts established in past permit cycles and to continue to strive for the objectives listed above. NCDOT will emphasize the importance of integrating educational initiatives into the development of tools, manuals, and guidance by the inclusion of training components within appropriate HSP projects and will expand the resources available to NCDOT staff, contractors, and the general public on the Department's websites. Additionally, NCDOT anticipates expanding training in some areas to provide increased assistance to Division staff. Communicating HSP training opportunities to Division staff and contractors as well as identifying training needs and developing specific training for staff and contractors throughout the state is an overarching internal education priority for the Department. NCDOT NPDES Permit NCS000250 ES-1 September 2019 _c - Highway S Internal Education Plan 1.0 Introduction to NCDOT HSP Internal Education Program The North Carolina Department of Transportation (NCDOT) established the Highway Stormwater Program (HSP) to support compliance with its National Pollutant Discharge Elimination System (NPDES) Permit (No. NCS000250) requirements, one of which is to develop an education program and Internal Education (IE) Plan. Under the HSP, the IE Program is responsible for developing the IE Plan and for providing education to appropriate NCDOT staff and contractors about their roles and responsibilities related to stormwater quality. The IE Program also helps support NCDOT's Environmental Stewardship Policy and NCDOT's mission of connecting people, products and places safely and efficiently, with customer focus, accountability and environmental sensitivity to enhance the economy and vitality of North Carolina by helping employees and contractors enhance their ability to protect water quality through education and training. The purpose of this IE Plan is to outline the goals and objectives of the IE Program and the framework within which NCDOT develops and distributes training materials. It also describes training required by NCDOT's NPDES Permit, requirements for reporting on training to North Carolina Department of Environmental Quality (NCDEQ), and examples of the required and additional training NCDOT has performed. This plan also provides a discussion of the internal education priorities for the Department. 1.1 Internal Education Program Goals and Objectives The IE Program supports successful implementation of the HSP and long-term compliance by striving to create "ownership" and internalization of pollution prevention practices through the involvement and education of program participants. The IE Program has the following goals: • Promote environmental awareness and personal accountability among NCDOT staff and contractors to meet NCDOT's NPDES Permit conditions and help achieve positive environmental results. • Document the educational activities and training opportunities already in place to comply with NDPES Permit conditions and NCDOT procedures. • Institutionalize stormwater education as an important and seamless part of NCDOT's way of doing business. • Use best available information, including new research results (from NCDOT-sponsored and other transportation -related research) and available technology tools and communication channels to improve the training program. To meet these overarching program goals, specific objectives were identified and are listed below, including Objectives 1 and 2 which were specified in NCDOT's permit. 1. Implement a program to train NCDOT staff and contractors about the importance of stormwater quality. 2. Incorporate topics such as spill control, chemical application, and identification of illicit discharges and illegal dumping into the training program. 3. Disseminate the results of NCDOT-sponsored and other transportation -related research to NCDOT staff and contractors in a timely and context -related manner. NCDOT NPDES Permit NCS000250 1-1 September 2019 _c - Highway StormwdN Y'.UGRAM Internal Education Plan 4. Develop training, guidance, and other outreach materials that are user-friendly, that relate to the user's job duties, and that are tailored to the targeted audience. 5. Integrate the development and dissemination of training materials into the development of tools, manuals, and practices created across the HSP. 6. Make training guidance and other outreach materials readily available and accessible to NCDOT staff, contractors, and the general public. 7. Document the HSP's educational practices and successes. Details about how NCDOT has implemented these objectives are provided in Section 2 of this plan. 1.2 Types of Training Included in IE Program For the purposes of this IE Plan, the term "internal education" may be defined broadly to include materials and experiences that enhance the acquisition, retention, and application of stormwater knowledge by NCDOT staff and contractors. The type of training, guidance, or outreach materials (collectively called educational materials) developed will depend on the complexity of the information or task, its intended audience or end -user, and whether it is a by-product or intermediate product of a larger program or deliverable. Educational materials must be prepared that target the role of the individual implementing the task and use language and technical terminology that correlate to the user's position and the job duties with which the stormwater task is associated. Therefore, to enhance learning and retention, the IE Program takes advantage of numerous educational opportunities to reach various target audiences with a wide range of information types. Examples of different types of educational materials include, but are not limited to, the following: • Formal classes with a curriculum and instructor or facilitator; • Computer -based coursework and distance learning; • Workshops, conferences, and meetings; • Discussions during staff meetings to discuss upcoming planned work; • Shadowing or on-the-job training; • Visual aids such as signs, posters, brochures, board postings, or other infographics with a stormwater message; • Sharing lessons learned and logging case studies and success stories; and • Written or verbal communication about new or existing tools and demonstration or evaluation of tools that aid in improving stormwater runoff quality or environmental protection. NCDOT NPDES Permit NCS000250 1-2 September 2019 _c - Highway Stormwat1.er Internal Education Plan Infographics showing treatment functions of stormwater control measures provide technical training in several NCDOT HSP guidance documents and training manuals The educational materials listed above are used to address three different types of training: • Awareness — to improve understanding of how NCDOT activities may affect stormwater quality and what may be done to minimize its impact • Procedural — protocols and "how-to training" • Technical — detailed training of the scientific or engineering principals that may improve work performance and the effectiveness of stormwater management techniques Utilizing a combination of these types of training contributes to the efficient execution and sustainability of NCDOT's HSP programs. 1.3 NPDES Permit Training and Reporting Requirements The IE Program primarily coordinates and supports the training initiatives and reporting requirements specified by NCDOT's NDPES permit, which are summarized in Table 1-1. Additional training, guidance, or informative materials related to stormwater quality and water quality are also supported by the IE Program. NCDOT NPDES Permit NCS000250 1-3 September 2019 _c - Highway Stormwater Internal Education Plan Table 1-1. Summary of NCDOT's NPDES Permit Training and Reporting Requirements Permit Requirement Requirement Description Reference Management Measure or Measurable Goal Training Requirements Part II.A. (a) Provide illicit discharge identification training. NCDOT shall provide annual Illicit Discharge training for appropriate staff and contractors. Training shall include identification Detection and and reporting of illicit discharges and illegal dumping. Elimination Program Part II.B.4. (c) Implement a BMP Inspection and Maintenance Program. The program will BMP Inspection and include annual training for appropriate NCDOT staff and contractors. Maintenance Program Part II.B.6. (c) Provide training on vegetation management. Provide annual training for Vegetation vegetation management personnel and contractors, or require equivalent training for Management Program contractors. The training shall consist of appropriate uses and applications of pest control methods used by NCDOT. This training shall be designed to increase awareness of proper mowing techniques, release of biological and chemical agents, appropriate spill response, the correct use and handling of products, and the potential for water quality impacts. Part II.C.1. While not specifically listed in the permit, NCDOT implements Erosion and Erosion and Sediment Sediment Control training as a part of the applicable requirements of the Control Program NCGO10000 General Permit for Construction Activities. Part II.C.2. (c) Borrow Pit Discharge Management Program. NCDOT, in coordination with Borrow Pit and Waste NCDEQ will implement the Borrow Pit Discharge Management Program. This Pile Activities program will consist of the following tasks: • Implement appropriate management measures to treat borrow pit wastewater for given conditions. • Implement an inspection and maintenance program. • Maintain training material and instruct field personnel overseeing borrow pit operations. • Evaluate and implement appropriate new/innovative technologies. Part II.D.2. (b).v. Employee Training. Training schedules shall be developed and training Industrial Activities provided at a minimum on an annual basis on proper spill response and cleanup procedures and preventative maintenance activities for all personnel involved in any of the facility's operations that have the potential to contaminate stormwater runoff Facility personnel (or team) responsible for implementing the training shall be identified in the [SPPP]. Part II.E. a. Provide pollution prevention awareness training for construction workers. Education and NCDOT shall provide annual stormwater pollution awareness training for Involvement Program — appropriate personnel and contractors involved in construction and maintenance 1. Internal Education activities. NCDOT may require contractors to have equivalent training in lieu of NCDOT-provided training. Training shall include general stormwater awareness, NPDES general stormwater permit NCGO10000 implementation, identification of stormwater pollution potential, appropriate spill response actions and contacts for reporting spills, and illicit discharges/illegal dumping. NCDOT NPDES Permit NCS000250 1-4 September 2019 _c - Highway Stormwater Internal Education Plan Table 1-1. Summary of NCDOT's NPDES Permit Training and Reporting Requirements (cont.) Permit Requirement Requirement Description Reference Management Part II.E. b. Provide pollution prevention awareness training for maintenance workers. Education and NCDOT shall maintain a program of annual stormwater pollution awareness Involvement Program — training for appropriate NCDOT maintenance staff. NCDOT shall also maintain an 1. Internal Education ongoing program for training Adopt -A -Highway volunteers. NCDOT may require contractors to have equivalent training in lieu of NCDOT-provided training. Training shall include general stormwater awareness, identification of stormwater pollution potential, and appropriate contacts for reporting spills and illicit discharges /illegal dumping, Part II.E. c. Provide pollution prevention awareness training for NCDOT staff. NCDOT Education and shall provide annual Stormwater Pollution Prevention Plan (SPPP) training for Involvement Program — appropriate NCDOT staff. Training shall include general stormwater pollution 1. Internal Education awareness, site -specific SPPP awareness, and reporting/documentation procedures. Part II.E. d. BMP Implementation Training. NCDOT shall provide training to appropriate Education and NCDOT personnel on implementation of post -construction BMPs in keeping with Involvement Program — the Toolbox, SCM I&M Manual, and the Post -Construction Stormwater Program 1. Internal Education (PCSP). NCDOT may require contractors to have equivalent training in lieu of NCDOT-provided training. Reporting Requirements Part III.A.2. a. Implementation of the SPPP at each NCDOT industrial facility shall include Stormwater Pollution documentation of related monitoring, measurements, inspections, maintenance Prevention Plans activities and training provided to employees. Such documentation shall be kept on - site for a period of five years and made available to NCDEQ immediately upon request. Part III.A.4. Training performed in conjunction with an SPPP requirement shall be documented Employee Training and maintained at the NCDOT facility as part of the SPPP. Part II.A.S. NCDOT shall maintain a list of positions responsible for implementing the Organizational Duties provisions of this permit including central office staff and divisional staff. The list and Responsibilities shall include positions, work addresses and phone numbers, and a brief description of their responsibilities and/or duties, training, and qualifications applicable to this permit. Descriptions of responsibilities and/or duties, training, and qualifications may be described separately and/or referenced to another document (i.e., training material, Spill Prevention Control and Countermeasure (SPCC) Plans, job descriptions, or in the employee's personnel record). Where more than one person is listed, one must be named as primary contact and others must be listed in the order in which they will assume responsibility as alternates. This list will be available upon request. 1.4 Internal Education Plan Maintenance As required by Part II.E.1.(e) of the 2015 permit, NCDOT will maintain the Internal Education plan, including the requirements of the Internal Education measurable goals noted above. The plan will be updated as needed. Updates might not be needed for minor changes in permit language for subsequent reauthorizations of the permit. NCDOT NPDES Permit NCS000250 1-5 September 2019 _c - Highway Stormwater Internal Education Plan 2.0 Implementation of Internal Education Program Objectives This section presents how the IE Program objectives are implemented by NCDOT, including a summary of the procedures used to establish and maintain the IE Program and meet NCDOT's NPDES Permit requirements. Additionally, examples for each objective are provided. It should be noted that the examples are not an exhaustive list of NCDOT's educational activities. Objectives 1 and 2 are also included in NCDOT's NPDES permit. 2.1 Objective 1: Implement a program to train NCDOT staff and contractors about the importance of stormwater quality. NCDOT implemented the IE Program during its Term I permit, issued in 1998. Since then, NCDOT has maintained the IE Program through dedication of manpower and funding for educational initiatives, and through planning for staff and contractor education on topics associated with stormwater quality. This IE Plan is an extension of the efforts to fulfill this objective. 2.2 Objective 2: Incorporate training topics such as spill control, chemical application, and identification of illicit discharges and illegal dumping into training program. NCDOT maintains ongoing and regular training for a wide range of topics. Specific training practices to meet this objective are listed in Table 2-1 below. Please note that Table 2-1 provides examples of ongoing training that specifically address Objective 2 of the IE Program and is not intended to be an exhaustive list of NCDOT's training practices. Table 2-1. Examples of Ongoing Training Stormwater Pollution Prevention Plan (SPPP) and SPCC Plan Training. Training for SPPPs (required in the NPDES Permit at Part II.E) and SPCC Plans (required for applicable facilities by 40 Code of Federal Regulations [CFR] 112) have been integrated into a single training program where individuals responsible for handling materials that may affect stormwater are trained in pollution prevention. Topics covered in this training include prevention and control of spills from fuel, oils, and other hazardous substances; control of bulk materials, such as salt and aggregate; identification of pollution potential; general housekeeping; procedures for inspecting facilities; illicit discharge and illegal dumping recognition and reporting; and reporting under the SPPP and SPCC. This program also meets some of the requirements at Part II.13.6 of the NPDES Permit (Vegetation Management). The training consists of procedural, awareness, and technical components. Individuals responsible for maintaining and implementing the SPPPs and SPCC Plans are regularly trained through in -person workshops and on -site visits. Supporting staff and material handlers are trained by these individuals using posters, brief announcements and reminders, and other materials. Additionally, the video modules "Stormwater Pollution Prevention: Doing Your Part," and "Spill Prevention and Response: Doing Your Part" which discuss these topics, are shown to new hires and annually to supporting staff and material handlers. NCDOT facilities document employee training and maintain SPPP training records on -site at the facilities. Contractors that operate temporary areas on NCDOT right-of-way that require an SPCC Plan or SPPP maintain separate plans and training programs for these areas. NCDOT NPDES Permit NCS000250 2-1 September 2019 _c - Highway Stormwater, Table 2-1. Examples of Ongoing Training (cont.) Erosion and Sediment Control and NCGO10000. NCDOT staff and contractors involved in construction activities receive procedural, technical, and awareness training on prevention and control of spills from fuel, oils, fertilizers, and other materials; control of bulk materials, such as soil and aggregate; identification of pollution potential; general housekeeping; procedures for inspecting facilities; illicit discharge and illegal dumping recognition and reporting; and reporting under the transportation —related requirements of the Construction General Permit (NCGO10000). Pollution prevention training and additional training for erosion and sediment control is provided for selected individuals through the North Carolina State University (NCSU) Erosion and Sediment Control Certification program. Vegetation Management — Chemical Application (Pesticide License). Application of regulated materials, such as pesticides or herbicides is performed by licensed professionals who have obtained the North Carolina Department of Agriculture and Conservation Service (NCDA&CS) Pesticide License, or staff directly under their supervision. This certification, issued by the NCDA&CS, requires ongoing training on topics including release of biological and chemical agents, appropriate spill response, the correct use and handling of products, and the potential for water quality impacts. Additionally, NCDOT offers Biennial Pesticide Recertification Training, presented by NCSU staff and other vegetation management professionals, where the latest safety and use information and research results are presented. This training satisfies a portion of the credits required by the NCDA&CS certification, and licensees must obtain additional recertification credits to maintain their license over a 3-year period. The aforementioned training opportunities also meet the requirements at Part II.E of the NPDES Permit. Internal Education Plan When contractors and NCDOT staff involved in construction activities obtain or are recertified through the Level II Site Supervisor training at NCSU, they complete and are tested on an NPDES module. Pollution prevention elements are incorporated in this module. Additionally, construction sites are audited monthly by NCDOT personnel to review compliance with the Department's NPDES Permit as well as applicable components of NCGO10000. The results of these audits may influence additional outreach efforts as needed. Selected individuals hold the NCDA&CS Pesticide License and are responsible for determining appropriate rates of chemical application and other requirements necessary to comply with NCDA&CS and Environmental Protection Agency (EPA) product restrictions. Vegetation Management — Mowing Techniques. Training and instruction are provided to Technical training regarding mowing techniques, such as individuals on an as -needed basis and through preferred grass heights, is provided individually to the contract specification during the implementation mowing staff or contractors. Additional mowing techniques of a specific mowing task. associated with structural BMPs are discussed in NCDOT's Stormwater Control Measure Inspection and Maintenance Manual. This training also meets the requirements at Part II.E of the permit. NCDOT NPDES Permit NCS000250 2-2 September 2019 _c - Highway Stormwater, Table 2-1. Examples of Ongoing Training (cont.) Internal Education Plan Training Description Participants/Schedule General Stormwater Pollution Prevention. In addition to The following example internal stormwater the SPPP training, other training on stormwater quality topics pollution prevention workshops and conferences is presented to applicable NCDOT staff through periodic are held: internal workshops and conferences. These presentations and 9 Roadside Field Operations Meeting training allow for targeted information to reach appropriate . Division Construction Engineers Conference staff in a timely and efficient manner. The training consists . Maintenance Engineers Conference primarily of procedural and awareness components. . Vegetation Management Conference Frequencies of these training conferences vary and are changed as needed by the Department. Winter Weather — Deicing Applications. Snow removal Managers and operators are trained to recognize and deicing training stresses the importance of estimating the the potential effects of forecasted storms, to amount of winter weather expected and the related level of determine the minimal level of deicing materials appropriate deicer applications. Calibration of the application necessary to maintain safe roadways, and to equipment is important to apply appropriate amounts without implement appropriate application techniques. exceeding established maximum levels, which balance the need for roadway safety with environmental concerns. Therefore, NCDOT has produced a video and calibration calculating spreadsheet to assist in the equipment calibration. Managers' training also includes reminders of additional NPDES topics such as salt storage at NCDOT maintenance yards. The training is supported by the National Weather Service. The training consists of procedural, awareness, and technical components. 2.3 Objective 3: Disseminate the results of NCDOT-sponsored and other transportation -related research to NCDOT staff and contractors in a timely and context -related manner. NCDOT HSP's Research Program, described in Part II.F of the NPDES Permit, routinely sponsors research projects with faculty and staff at state universities and other designated institutions, such as the United States Geological Survey (USGS), to provide an independent quantitative assessment of stormwater from NCDOT's permitted activities, measure of structural BMP effectiveness, or evaluate BMP design techniques. When the research results indicate that modifications to current NCDOT practices are warranted to reduce the potential for environmental impacts, the IE Program and other HSP program areas may assist with disseminating the information to appropriate parties. Two examples of this relationship between the IE Program, Research Program, and other HSP programs are provided below. 1. Research results from NCSU and the University of North Carolina Charlotte (UNCC) have been incorporated in the latest version of the NCDOT Stormwater BMP Toolbox. NCDOT's BMP Toolbox is made available to NCDOT design engineers and consultants through NCDOT's Connect website. 2. Research projects are also used as opportunities to train HSP staff. For example, in 2016 when multiple bioswales were constructed at NCSU's Soil and Erosion Control Research and NCDOT NPDES Permit NCS000250 2-3 September 2019 _c - HigShway rk OGRhN Internal Education Plan Education Facility (SECREF), NCDOT staff from the HSP were on hand to observe construction procedures and discuss applicability to the roadway or non -road environment. 2.4 Objective 4: Develop training, guidance, and other outreach materials that are user-friendly, that relate to the user's job duties, and that are tailored to the targeted audience. NCDOT staff and contractors, from technicians and operators to mid- and upper -level management, engage in a wide variety of tasks to implement and maintain structural and non-structural BMPs. Activities vary in complexity and assigned staff, therefore, educational materials must be prepared that target the role of the individual implementing the task and that use language and technical terminology that correlate to the user's position and the job duties with which the stormwater task is associated. Consequently, NCDOT's IE Program and other HSP programs generate various types of educational materials, including: 1. Informational industrial activity flyers — Taking the form of mini -posters, these flyers address topics associated with the SPPP and include text to facilitate training of supporting staff and material handlers by the SPPP managers. 2. Maintenance posters — Graphical posters that address topics associated with maintaining industrial and roadway facilities are developed and distributed annually. The posters and topics are integrated into NCDOT's Industrial and Roadway Maintenance Activities BMP Guidance Manual (or IRMA Manual) as appropriate. 3. Presentations for technical staff at internal conferences — Examples include presentations on identifying and reporting illicit discharges and illegal dumping, presented at the Roadside Conference, and compliance with the proposed effluent guidelines for stormwater associated with construction, presented during NCDOT's Division Construction Engineers' Conference or NCDOT's Maintenance Engineer's Conference. 4. Targeted NCDOT Workshops for technical staff — Dissemination of lessons learned and new research and collaboration on techniques are examples of topics discussed at targeted technical workshops. For example, as the HSP Stormwater Outfall Inventory and Prioritization Program (SOIPP) Field Inventory procedure was developed, a need for training on appropriate quality control procedures for the newly developed geospatial data was identified. Training on developing and using topology rules to review and clean-up geospatial datasets was provided to the NCDOT engineers working in that program. 2.5 Objective 5: Integrate the development and dissemination of training materials into the development of tools, manuals, and practices created across the HSP. Through the HSP, NCDOT continues to create numerous tools, manuals, and guidance documents to meet permit requirements and to address the Department's stormwater quality and water quality initiatives outlined in its Environmental Stewardship Policy. Such materials are developed by groups of NCDOT staff, technical experts, and other stakeholders (such as end users and researchers). The development NCDOT NPDES Permit NCS000250 2-4 September 2019 _c - Highway YkGGRAM Internal Education Plan process typically includes tasks to produce educational materials to facilitate the dissemination of the new or updated information and procedures. NCDOT continues to emphasize the importance of integrating the distribution of educational materials into the development of tools, manuals, and guidance documents by requiring that a training component be considered with each project under the HSP. Guidance on selecting the appropriate training techniques and materials was developed for HSP project managers and is being applied to current and future projects. Some examples of ongoing and existing integration of educational initiatives into product development are described below. NCDOT's Stormwater Control Management System (SCMS) was developed as a web -based tracking protocol for inventorying structural BMPs, recording inspections, and documenting maintenance needs and maintenance performed under the Inspection and Maintenance (I&M) Program. At the completion of the development and testing efforts, a training program - which included a workshop with tests - was developed and implemented to train Division Roadside Environmental Engineers (DREEs) and staff and other HSP staff on how to use SCMS. Training videos were developed and distributed to staff with the original release of SCMS, and were updated after a major update of SCMS in 2015. 2. NCDOT funded multiple NCSU projects to evaluate the effectiveness of various BMPs, including a dune infiltration system and a biofiltration conveyance. As a deliverable of these tasks, NCSU provided information for posters that discussed the research results and provided information on selected design components. The poster pictured below is used during various conferences and meetings, such as a Low Impact Development Workshop, to educate the hydraulic engineers and others on biofiltration conveyance controls. As appropriate, BMPs studied will be integrated into the NCDOT BMP Toolbox or used in the Retrofit Program. Example of educational posters developed by HSP NCDOT NPDES Permit NCS000250 2-5 September 2019 _c - Highway rk S GGR M Internal Education Plan 3. NCDOT's Stormwater Management Plan (SMP) was developed as a spreadsheet tool to assist design engineers in their analysis of evaluating potential impacts to surface waters. The SMP was revised and provided to internal and external design engineers during Permit Term I11. An e-learning module with instructions on completing the SMP was developed and made available to staff and to contractors through NCDOT's YouTube channel. 4. NCDOT's IRMA Manual was developed as a training tool that covers a wide range of maintenance activities. Chapters focus on how to implement practices that are protective of stormwater quality, and include training guides, quizzes that test for understanding, and site - specific discussion questions so facilities can pinpoint problem areas that require additional focus. NCDOT supported development of a nutrient accounting tool, the NCDOT-JLSLAT, in order to meet nutrient management requirements under the Guided Reduction of Excess Environmental Nutrients (GREEN) Program. A series of six training videos were prepared by NCDOT to support staff and contractors when using the tool on new non -road development projects. The 8-12 minute videos cover topics such as an introduction to the GREEN Program, an overview of NCDOT-JLSLAT, model routing scenarios, simple and complex site examples and how to "set-up" a new project using NCDOT-JLSLAT. The videos are made available to staff and contractors on the NCDOT YouTube channel. 2.6 Objective 6: Make training, guidance, and other outreach materials readily available and accessible to NCDOT staff, contractors, and the general public. While many of NCDOT's structured educational programs (such as SPPP) include actively delivering training in person or through NCDOT's existing career -related training programs, NCDOT is working to develop more tools, guidance, and other materials available for reference online. Self -serve training materials must be readily available from resources where they will logically be sought, such as the state's learning management system (LMS), the NCDOT intranet, or NCDOT's public websites. Examples include the following: Since the inception of the HSP, many tools and guidance documents for developing and implementing erosion and sediment controls have been made available to NCDOT staff, contractors, and the public on several different NCDOT websites. Materials available include guidance documents describing the function and limitations of erosion and sediment control measures, a description of the plan development and review process, special provisions and details that can be used to develop plans, and downloadable spreadsheets that assist in calculating basin volumes and matting quantities and in addressing watershed -specific requirements. NCDOT's Connect website provides a centralized repository that makes it easier for users to find related documents through one site. 2. NCDOT's BMP Toolbox and Stormwater Control Inspection and Maintenance Manual were both developed to instruct users on design and I&M techniques and are used regularly as references by NCDOT staff and contractors. Additionally, both manuals include checklists as tools to facilitate the respective programs. These resources have been made available on NCDOT's Connect website. NCDOT NPDES Permit NCS000250 2-6 September 2019 _c - Highway rk_ Swjio� Internal Education Plan 3. The Multi -Sensor Precipitation Estimates (MPE) tool is used by NCDOT and its contractors to fulfill NCGO10000 requirements to mobilize for inspection of construction sites following threshold rainfall events and for maintaining precipitation records. As new NCDOT employees and contractors begin work on construction projects, training for the MPE is available for their use. 4. The online Environmental Sensitivity Map (ESM) application and database were developed for the HSP to provide NCDOT staff and contractors with access to interactive maps of transportation and environmental data through a browser, removing the need for an ArcGIS license. The maps are used to identify environmentally sensitive features located near Transportation Improvement Project sites and to track discharge locations and BMPs. Simple searches can be used to quickly zoom to an NCDOT Division or a county. The maps are available to all users through a link on the Connect NCDOT website. Users may also access ESM training videos on the NCDOT YouTube channel through a link on Connect NCDOT website. The HSP has begun using the state's LMS to deliver training to team members and to track training completed by employees. In addition to offering instructor -led courses through the LMS, HSP is developing additional e-learning modules that employees and contractors can take on demand. 2.7 Objective 7: Document the HSP's educational practices and successes. Documenting NCDOT's successes in implementing the HSP and associated reductions in potential stormwater pollution effectively keeps environmental stewardship "on the radar" of NCDOT staff and contractors. Dissemination of these success stories is facilitated through NCDOT's website and intranet to further promote awareness. Additionally, the HSP has established a strong relationship with the Department's Communications Office and has contributed to environmental videos and stories posted to NCDOT's intranet. These internal stories not only publicize the successes of the HSP, they provide simple yet essential environmental information. NCDOT training session Additionally, NCDOT documents training and other educational initiatives performed under the HSP. The method used for tracking is dependent upon the type of training provided, as described below. LMS Training Rosters. The NC Learning Center — the state's web -access learning management system — is currently used to track all training required of and completed by NCDOT employees. Any HSP training that is managed or delivered through the state's LMS is documented through the registration process. Procedures for adding and managing HSP training to the LMS have been developed; the procedures also describe several different processes for adding trainee rosters. Using LMS reporting tools, HSP management will be NCDOT NPDES Permit NCS000250 2-7 September 2019 _c - Highway StormuAN OF Internal Education Plan able to view lists of trainees by year or by course; transcripts for individual employees will also show any stormwater-related training completed by that individual. Onsite Documentation. Other training performed for NPDES compliance that is site - specific is documented at the individual location. For example, documentation of SPPP training provided to Division staff regarding SPPP implementation is documented via sign -in sheets maintained in the Division Offices. Information tracked using this method includes employee names, course topics, training date, and instructors' names. Attendee lists and agendas of bull -pen meetings to discuss stormwater concerns or pollution prevention techniques are also maintained at the Division Offices, due to their nature to be brief, frequent and in the context of other operational meetings. If slides or handouts are used with such trainings, these materials are kept in the same files. These records are maintained for a minimum of five years, as required by the NPDES permit. Supplemental tracking under the IE Program. For the purpose of compliance reporting under the NPDES permit, the IE Program tracks the existence of the training otherwise documented in the LMS and through onsite documentation. Additional training that may not fit well within the mechanisms above is tracked by the IE Program via internal record keeping. Information tracked is dependent upon the type of training. For example, ad hoc consultation for BMP designs or pollution prevention are not specifically documented but are recorded as being offered. For training performed outside of NCDOT, such as BMP design training offered at NCSU, and training received by selected consultants supporting the HSP, the IE Program documents the participant's name, training completed, date, and links to the training curriculum, when available. These records are maintained for a minimum of five years, as required by the NPDES permit. NCDOT also reports on its on stormwater-related training activities through its NPDES Annual Report submitted to the NCDEQ each year. NCDOT NPDES Permit NCS000250 2-8 September 2019 Highway o Internal Education Plan 3.0 NCDOT NPDES Permit Priorities NCDOT intends to continue the educational efforts established in past permit cycles and to continue to apply the objectives discussed above. NCDOT will focus on integrating an educational component into new and updated tools, manuals, and guidance. NCDOT will also continue to deploy resources to NCDOT staff, contractors, and the general public through the Department's internet sites. NCDOT anticipates developing training in new areas as they are incorporated into the HSP or need to be addressed under NCDOT's Environmental Stewardship Policy. Department priorities are described below. NCDOT's organizational structure has changed, with Divisions assuming more responsibility for design and construction projects which has implications for the implementation of the various programs such as the PCSP and the training associated with these programs. The HSP will therefore need to provide additional stormwater training to the practitioners in these units. A key focus in the new term will be to identify Division training needs, identify educational delivery approaches, and implement this training. 3.1 Erosion Control Training for Construction Workers HSP will continue to provide annual updates on erosion control and other stormwater management topics for construction workers (management measure a) through the Construction Engineers Conference as well as continuing existing training programs and certifications. In addition, on -demand training is available through guidance and procedures posted on NCDOT's website. 3.2 Pollution Prevention Training for Maintenance Workers HSP will continue to provide stormwater awareness programs for maintenance workers (management measure b) through DOT -sponsored activities such as the Vegetation Management Conference and training for Adopt -A -Highway volunteers, and through recognition of training provided by others (such as NCSU). 3.3 Pollution Prevention Training for NCDOT Staff HSP has maintained a robust annual SPPP/SPCC train -the -trainer program for NCDOT staff (management measure c) and will continue to use this established mechanism for delivering updated stormwater management information. Two levels of training are provided to the NCDOT Divisions: Level 1 is for new workers and covers basic pollution prevention topics; Level 2 is provided for workers who have already taken Level 1 and provides updates on new procedures and guidance. New topics are incorporated in this training each year to keep the material up-to-date. 3.4 PCSP and BMP Implementation Training With the publication of the updated PCSP guidance, BMP Toolbox and SMP during Term III, HSP launched new training initiatives to make staff and contractors aware of the changes to the tools and the guidance. Responsibility for training for these tools was assigned to the IE program (management measure d). HSP will focus on making the general guidance and training (developed during Term III) available to a wider audience as well as developing new training materials for specific audiences as the need is identified. NCDOT continues to develop an ongoing training program associated with its BMP Toolbox. The training will focus on educating NCDOT and consultant design engineers on the critical design components for the linear system as described in the NCDEQ-approved BMP Toolbox, with updates to the training as new approved BMPs are incorporated into the BMP Toolbox. NCDOT NPDES Permit NCS000250 3-1 September 2019 Highway ,-Internal Education Plan NCDOT developed and delivered in -person training for in-house design staff and will continue to provide classroom training for selected staff. NCDOT also developed PCSP and SMP e-learning modules which were made available to staff and contractors through the LMS. The in -person training covers implementation of the BMP Toolbox, design components for approved BMPs, and the importance of considering maintenance needs and access for the long-term functionality of the BMP. This training also reviews the use of NCDOT's SNIP, a form for the documentation of site -specific characterizations and information used during the design process. The poster below is an example of educational materials included in the BMP Toolbox. Pollutants found in rainfall runoff can be harmful to the arvimnmanl- In an effort to reduce the amount of pollutants found in runoff water, atormwater treatment day leas are being utilized on this rest area "0' One such daylCa is a bioretendon basin as illustrated to the right A bioretenfion basin is a shallow planted depression designed to retain, filter and treat runoff water prior to its discharge Imo the neatest sheen, rbyar Of lake, all ring rainfall events, runoff water collected from the sidewalks, parking lots and roadway :unlaces is piped Imo a sediment forebay where water flow is slowed and heayiar parriclas are allowed to settle. As runoff water flows from the fambay into Ifie basin if slowly soaks through layers of sail and mulch. Pollutant removal takms place by way of absorption, microbial activity, plant uptake and filtration. Once treated, the water is released from tho basin Landscaping is critical to the function and appearance of a% hioretention hasins- Plarus are needed to encourage hie logical and bacteriological actieity in the soil and to establish a diverse 'egetaiive cover that will aid in the treatment of stornnvater runoff Ihrough the capture of pollutants. Plants used in bioralemion basins are selected for their ahi lily to adapt to periods of both wet and dry conditions while surviving high levels of polWtant build-up. Since most hioratanrion basins are designed to replicate the functlons of a native forest ecosystem, a Combination of trees, shrubs, grasses and herbaceous plants are used. Plants tolerant Of sfiart•lerm flooding are used in the shallow depression area of the basin where runoff water is retained, filtered and treated, At the basin's edge and on its side slopes that remain primariPy dry. upland species are most suiled. Piclured are a fern of The native plant spat lea typically used in our bioretention basins. through an underdra in system and underdrain system. Rain gardens are "tat pipe, asp"lly appealing to homeowners and small 6usinessey beoauee of their Diomlention basins are better known ease of installation. beauty and low as rain gardens. While the two terms maintenance requirements. They can be may he used interchangeably, rain sized and shaped to I$ arty application gardens are usually bui 11 on a much and landscaped with a variety of plants smaller scale and do rut have an to compliment any surrevnding. Example of Toolbox Training Materials 3.5 Highway Stormwater Website for Business Partners As NCDOT's organizational structure evolves and staff changes, maintaining awareness about roadway stormwater runoff will remain a top priority. The redesign of the NCDOT's Connect website provides a central repository and a means for providing context for the various HSP products. HSP will continue to promote the use of this site and will continue to post new information on the site. NCDOT will continue to make relevant documents discoverable through the HSP Connect pages. This means that either the documents are loaded on HSP pages or a link from HSP to their location on other pages is provided from an HSP page. The information shown on the website not only reminds staff about the impact of NCDOT activities on the environment but also garners an appreciation for what NCDOT HSP does. HSP will also continue working with the NCDOT Communication Office to publicize and identify education opportunities NCDOT NPDES Permit NCS000250 3-2 September 2019 Highway o—Internal Education Plan through existing channels such as Connect NCDOT, the Department's public facing website, and the HSP YouTube site. 3.6 Nutrient Management The Jordan Reservoir Water Supply Nutrient Rules (Jordan Lake Rules), promulgated under 15A North Carolina Administrative Code (NCAC) 02B.0271, requires a Nutrient Management Education Program. Under this Program, NCDOT staff and contractors that apply inorganic fertilizers and organic nutrients on highway rights -of -way in the Jordan Lake watershed (which includes portions of Divisions 5, 7, 8, and 9) are required to complete nutrient management training provided by the North Carolina Division of Water Resources and obtain a certificate of completion. A certificate indicates successful completion of nutrient management training. Each nutrient application crew should have a minimum of one certificate holder on site. Contractors will be required to provide proof of participation in the NC Cooperative Extension Service training by furnishing documentation to the Engineer at the preconstruction conference. Training material and information on obtaining a certificate is available online on NCDEQ's website. NCDOT has developed the GREEN Program in response to the Jordan Lake Rules. Phase I of the program implementation focused on developing SMPs for new roadway development. The GREEN Program integrates and enhances NCDOT's stormwater and nutrient management practices to support compliance with the Jordan Lake Rules as a total maximum daily load (TMDL) contributor. NCDOT NPDES Permit NCS000250 3-3 September 2019 Highway Internal Education Plan 4.0 Sustaining the Internal Education Program An underlying principle of the HSP IE Program is the idea of sustainability. A sustainable education program is one that is resilient over time, can address new needs, and can weather changing resources. It requires the buy -in, cooperation, and support of the leaders of the other HSP program areas as well as of NCDOT management. Compliance with the requirements of NCDOT's NPDES permit will continue to be the HSP's driving goal. NCDOT's documented internal education events show a variety of times, places, and methods by which training is delivered. NCDOT is confident that the various trainings satisfy the requirements of the permit and provide a basis for addressing stormwater quality. Continuing efforts to make the IE Program sustainable will focus on the following principles: 1. Using available in-house protocols and online tools to document training quickly, consistently, and uniformly. Long-standing practices like keeping training attendance sheets as training records and online systems like the LMS can both play a role. 2. Continuing to emphasize importance of including training and communication as intrinsic elements of HSP tools, programs, or database projects. For example, as new chapters of the BMP Toolbox are planned, a training plan and communication plan should be considered. 3. Forming partnerships with government, non-profit, and academic institutions to provide the training. Currently, NCSU provides erosion and sediment control training for NCDOT staff, contractors, and consultants. 4. Organizing training opportunities by job class or type. For example, Erosion and Sediment Control/Stormwater Certification is currently offered at three levels for three job classes: a) Level I Installer or Inspector certification is for a contractor who installs erosion and sediment control BMPs or an Inspector, (an NCDOT technician or consultant) who inspects BMPs. b) Level II Site Management certification is for a foreman of a crew involved in land disturbing activities (grading contractors) or in work over jurisdictional water (bridge contractors) or an NCDOT technician, engineer, contractor, or consultant who performs NPDES record keeping. c) Level III Plan and Reclamation Plan Design certification is for consultants, contractors, and NCDOT engineers or technicians who design or approve the design of erosion and sediment control plans. NCDOT NPDES Permit NCS000250 4-1 September 2019