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HomeMy WebLinkAboutNCS000434_Archdale Draft SWMP v1_20201026 Stormwater Management Plan City of Archdale NCS000434 March 5, 2020 Table of Contents PART 1: INTRODUCTION ........................................................................................................................ 1 PART 2: CERTIFICATION ........................................................................................................................ 2 PART 3: CITY OF ARCHDALE INFORMATION ................................................................................... 3 3.1 Permitted City of Archdale Area .................................................................................................. 3 3.2 Existing City of Archdale Mapping .............................................................................................. 3 3.3 Receiving Waters .......................................................................................................................... 5 3.4 City of Archdale Interconnection .................................................................................................. 6 3.5 Total Maximum Daily Loads (TMDLs) ....................................................................................... 6 3.6 Endangered and Threatened Species and Critical Habitat ............................................................ 7 3.7 Industrial Facility Discharges ....................................................................................................... 7 3.8 Non-Stormwater Discharges ......................................................................................................... 7 3.9 Target Pollutants and Sources ....................................................................................................... 8 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 10 4.1 Organizational Structure ............................................................................................................. 10 4.2 Program Funding and Budget ..................................................................................................... 11 4.3 Shared Responsibility ................................................................................................................. 11 4.4 Co-Permittees .............................................................................................................................. 13 4.5 Measurable Goals for Program Administration .......................................................................... 13 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 15 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 17 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 18 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................... 21 PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 23 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ...................... 29 List of Tables Table 1: Summary of City of Archdale Mapping Table 2: Summary of City of Archdale Receiving Waters Table 3: Summary of Approved Total Maximum Daily Loads Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality Table 5: National Pollutant Discharge Elimination System Stormwater Permitted Industrial Facilities Table 6: Non-Stormwater Discharges Table 7: Summary of Target Pollutants and Sources Table 8: Summary of Responsible Parties Table 9: Shared Responsibilities Table 10: Co-Permittee Contact Information Table 11: Program Administration Best Management Practices Table 12: Summary of Target Pollutants & Audiences Table 13: Public Education and Outreach Best Management Practices Table 14: Public Involvement and Participation Best Management Practices Table 15: Illicit Discharge Detection and Elimination Best Management Practices Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Table 17: Construction Site Runoff Control Best Management Practices Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program Table 19: Summary of Existing Post-Construction Program Elements Table 20: Post Construction Site Runoff Control Best Management Practices Table 21: Pollution Prevention and Good Housekeeping Best Management Practices NCS000434 SWMP City of Archdale March 5, 2020 Page 1 PART 1: INTRODUCTION The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the City of Archdale will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent practicable. This SWMP identifies the specific elements and minimum measures that the City of Archdale will develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with the Municipal Separate Storm Sewer System Permit number NCS000434, as issued by North Carolina Department of Environmental Quality. This permit covers activities associated with the discharge of stormwater from the Municipal Separate Storm Sewer System as owned and operated by the City of Archdale and located within the corporate limits of the City of Archdale. In preparing this Stormwater Management Plan, the City of Archdale has evaluated its Municipal Separate Storm Sewer System and the permit requirements to develop a comprehensive 5-year Stormwater Management Plan that will meet the community’s needs, address local water quality issues and provide the minimum measures necessary to comply with the permit. The Stormwater Management Plan will be evaluated and updated annually to ensure that the elements and minimum measures it contains continue to adequately provide for permit compliance and the community’s needs. Once the Stormwater Management Plan is approved by North Carolina Department of Environmental Quality, all provisions contained and referenced in this Stormwater Management Plan, along with any approved modifications of the Stormwater Management Plan, are incorporated by reference into the permit and become enforceable parts of the permit. NCS000434 SWMP City of Archdale March 5, 2020 Page 2 PART 2: CERTIFICATION By my signature below I hereby certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. I am also aware that the contents of this document shall become an enforceable part of the National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System Permit, and that both the Division and the Environmental Protection Agency have National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System Permit compliance and enforcement authority. ☐ I am a ranking elected official. ☐ I am a principal executive officer for the permitted Municipal Separate Storm Sewer System. ☒ I am a duly authorized representative for the permitted Municipal Separate Storm Sewer System and have attached the authorization made in writing by a principal executive officer or ranking elected official which specifies me as (check one): ☒ A specific individual having overall responsibility for stormwater matters. ☐ A specific position having overall responsibility for stormwater matters. Signature: Print Name: David Joseph Señeres, PE Title: Stormwater Program Manager Signed this 5th day of 2020 . NCS000434 SWMP City of Archdale March 5, 2020 Page 3 PART 3: MS4 INFORMATION 3.1 Permitted Municipal Separate Storm Sewer System Area This Stormwater Management Plan applies throughout the corporate limits of the City of Archdale, including all regulated activities associated with the discharge of stormwater from the Municipal Separate Storm Sewer System. The map below shows the corporate limits of the City of Archdale as of the date of this document. 3.2 Existing MS4 Mapping The current Municipal Separate Storm Sewer System mapping includes a depiction 2 segments of jurisdictional waterways existing within the current jurisdictional city limits. The segments are defined as portions of Muddy Creek [WS-IV 17-(9)-01] and portions of Caraway Creek [Class C 13-2-3]. The existing mapping depicts 5 catchments, 135 sub-catchments, and 518 sub-basins. Between the initial implementation of the ACE Integrated Stormwater Management Program, the length of jurisdictional miles increased from 5.89 to 6.31 miles with the Annexation of a future development area known as the former Spillman Christmas Tree Farm circa, 2006. The length of jurisdictional waters within the corporate city limits of Archdale has not changed since the implementation of existing Stormwater Management Plan on January 2, 2008 and remains at 6.31 miles. NCS000434 SWMP City of Archdale March 5, 2020 Page 4 NCS000434 SWMP City of Archdale March 5, 2020 Page 5 Table 1: Summary of MS4 Mapping Percent of Municipal Separate Storm Sewer System Area Mapped 100 % No. of Major Outfalls* Mapped 38 total *An outfall is a point where the Municipal Separate Storm Sewer System discharges from a pipe or other conveyance (e.g. a ditch) directly into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major outfall is a 36-inch diameter pipe or discharge from a drainage area > 50- acres; and for industrial zoned areas a 12-inch diameter pipe or a drainage area > 2-acres. 3.3 Receiving Waters The City of Archdale Municipal Separate Storm Sewer System is located within the Cape Fear River Basin and the Yadkin Pee Dee River Basin and discharges directly into receiving waters as listed in Table 2 below. Applicable water quality standards listed below are compiled from the following North Carolina Department of Environmental Quality sources: o Waterbody Classification Map NCS000434 SWMP City of Archdale March 5, 2020 Page 6 o Impaired Waters and TMDL Map o Most recent NCDEQ Final 303(d) List Table 2: Summary of MS4 Receiving Waters Receiving Water Name Stream Index / AU Number Water Quality Classification 303(d) Listed Parameter(s) of Interest Muddy Creek 17-(9)-01 WS-IV None Caraway Creek 13-2-3 Class C None 3.4 MS4 Interconnection The City of Archdale Municipal Separate Storm Sewer System is not interconnected with another regulated Municipal Separate Storm Sewer System and directly discharges to the receiving waters as listed in Table 2 above. 3.5 Total Maximum Daily Loads (TMDLs) The TMDL(s) listed in Table 3 below have been approved within the Municipal Separate Storm Sewer System area, as determined by the map and list provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program has been implemented to address the WLA. Table 3: Summary of Approved TMDLs Water Body Name TMDL Pollutant(s) of Concern Stormwater Waste Load Allocation (Y/N) Water Quality Recovery Program (Y/N) None None N N NCS000434 SWMP City of Archdale March 5, 2020 Page 7 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endangered species and/or critical habitat are not identified within the regulated Municipal Separate Storm Sewer System urbanized area, as determined by a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Map and Listed species believe to or known to occur in North Carolina map as provided by the U.S. Fish and Wildlife Service. Of those species listed, Table 4 summarizes the species that may be significantly impacted by the quality of surface waters within their habitat. Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality Scientific Name Common name Species Group Federal Listing Status None None None None 3.7 Industrial Facility Discharges The City of Archdale Municipal Separate Storm Sewer System jurisdictional area includes the following industrial facilities which hold National Pollutant Discharge Elimination System Industrial Stormwater Permits, as determined from the National Pollutant Discharge Elimination System Active NPDES Stormwater Permit List and/or Active Stormwater Permits Map. Table 5: National Pollutant Discharge Elimination System Stormwater Permitted Industrial Facilities Permit Number Facility Name NCG080184 United Parcel Service Inc, 1205 Corporation Drive NCG030009 Thomas Built Busses Inc 715 W Fairfield Road NCGNE510 Hubbell ICD 4301 Cheyenne Drive NCGNE0024 Costa & Grissom Machinery Co 107 Seminole Drive NCGNE0748 Ornamental Products LLC 3804 Comanche Drive NCGNE1244 Brookline Furniture Company LLC 4014 Cheyenne Drive NCGNE1242 Brookline Furniture Company LLC 4012 Cheyenne Drive NCGNE1245 Brookline Furniture Company LLC 4015 Cheyenne Drive 3.8 Non-Stormwater Discharges The water quality impacts of non-stormwater discharges have been evaluated by the City of Archdale as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. The City of Archdale has evaluated residential and charity car washing and street washing for possible significant water quality impacts. Street washing discharges are addressed under the Pavement Management Program in Part 10 of this Stormwater Management Plan. The Division has not required that other non-stormwater flows be specifically controlled by the City of Archdale NCS000434 SWMP City of Archdale March 5, 2020 Page 8 Wash water associated with car washing that does not contain detergents or does not discharge directly into the Municipal Separate Storm Sewer System is considered incidental. However, these types of non- stormwater discharges that do contain detergents have been evaluated by the Municipal Separate Storm Sewer System to determine whether they may significantly impact water quality. Based on the community needs and observations, the City of Archdale has not observed residential and charity car washing and street wash water usage which would justify moving from “incidental” to “possible.” Table 6: Non-Stormwater Discharges Non-Stormwater Discharge Water Quality Impacts Water line and fire hydrant flushing Incidental Landscape irrigation Incidental Diverted stream flows Incidental Rising groundwater Incidental Uncontaminated groundwater infiltration Incidental Uncontaminated pumped groundwater Incidental Uncontaminated potable water sources Incidental Foundation drains Incidental Air conditioning condensate Incidental Irrigation waters Incidental Springs Incidental Water from crawl space pumps Incidental Footing drains Incidental Lawn watering Incidental Residential and charity car washing Incidental Flows from riparian habitats and wetlands Incidental Dechlorinated swimming pool discharges Incidental Street wash water Incidental Flows from firefighting activities Incidental 3.9 Target Pollutants and Sources In addition to those target pollutants identified above, the City of Archdale is not aware of other significant water quality issues within the permitted City of Archdale area. The City of Archdale continues to monitor non-point source items of trash, sediment transport (non-construction), and petroleum products on the roads due to visitors traveling through Main Street to access I-85. Currently, construction in the city has been limited to three restaurants and approximately 65 residential homes located in the Muddy Creek catchment and the Caraway Creek catchment over the last 15 years. Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this Stormwater Management Plan, the likely activities/sources/targeted audiences attributed to each pollutant, and identifies the associated Stormwater Management Plan program(s) that address each. In addition, the City NCS000434 SWMP City of Archdale March 5, 2020 Page 9 of Archdale has evaluated schools, homeowners and businesses as target audiences that are likely to have significant stormwater impacts. Based on the evaluation of schools, homeowners and businesses as target audiences, no significant stormwater impacts exist as a result of community needs and the target pollutants for those that are minimal based on observations. Table 7: Summary of Target Pollutants and Sources Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing Target Pollutant(s)/Audience(s) Litter Residents, Businesses, Schools Public Education & Outreach NCS000434 SWMP City of Archdale March 5, 2020 Page 10 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure Table 8: Summary of Responsible Parties SWMP Component Responsible Position Staff Name Department Stormwater Program Administration Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Stormwater Management Plan Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Public Education & Outreach Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Public Involvement & Participation Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Illicit Discharge Detection & Elimination Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Construction Site Runoff Control Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Post-Construction Stormwater Management Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Pollution Prevention/Good Housekeeping for Municipal Operations Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management NCS000434 SWMP City of Archdale March 5, 2020 Page 11 Municipal Facilities Operation & Maintenance Program Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Spill Response Program Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management MS4 Operation & Maintenance Program Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Municipal Stormwater Control Measures Operation & Maintenance Program Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Pesticide, Herbicide & Fertilizer Management Program Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Vehicle & Equipment Cleaning Program Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Pavement Management Program Stormwater Program Manager David Joseph Señeres, PE, PWLF Stormwater Management Total Maximum Daily Load (TMDL) Requirements None None None 4.2 Program Funding and Budget In accordance with the issued permit, the City of Archdale shall maintain adequate funding and staffing to implement and manage the provisions of the Stormwater Management Plan and comply with the requirements of the National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System Permit. The budget includes the permit administering and compliance fee, which is billed by the Division annually. Since implementation, the Enterprise Fund is adequate for the community needs as reviewed annually by the Stormwater Manager during budget which is approved annually by Council typically during the May Council Meeting; Only on the rare occasion does the budget approval extend into June as during the 2020 cycle due to COVID-19 4.3 Shared Responsibility The City of Archdale will share the responsibility to implement the following minimum control measures, which are at least as stringent as the corresponding National Pollutant Discharge Elimination System NCS000434 SWMP City of Archdale March 5, 2020 Page 12 Municipal Separate Storm Sewer System Permit requirement. The City of Archdale remains responsible for compliance if the other entity fails to perform the permit obligation, and may be subject to enforcement action if neither the City of Archdale nor the other entity fully performs the permit obligation. Table 9 below summarizes who will be implementing the component, what the component program is called, the specific Stormwater Management Plan Best Management Practice or permit requirement that is being met by the shared responsibility, and whether or not a legal agreement to share responsibility is in place. Stormwater Management Plan Best Management Practices or Permit Requirement Implementing Entity & Program Name Legal Agreement (Y/N) Auxillary Component Piedmont Triad Council Council of Government Y Table 9: Shared Responsibilities Stormwater Management Plan Best Management Practices or Permit Requirement Implementing Entity & Program Name Legal Agreement (Y/N) Not Applicable NCS000434 SWMP City of Archdale March 5, 2020 Page 13 4.4 Co-Permittees The are no other entities applying for co-permittee status under the National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System permit number NCS000434 for the City of Archdale. Table 10 summarizes contact information for each co-permittee. Table 10: Co-Permittee Contact Information Co-Permittee Municipal Separate Storm Sewer System Name Contact Person Phone & E-Mail Interlocal Agreement (Y/N) Not Applicable 4.5 Measurable Goals for Program Administration The City of Archdale will manage and report the following Best Management Practices (BMPs) for the administration of the Stormwater Management Program. Table 11: Program Administration Best Management Practices Permit Ref. 2.1.2 and Part 4: Annual Self-Assessment Measures to evaluate the performance and effectiveness of the Stormwater Management Plan program components at least annually. Results shall be used by the permittee to modify the program components as necessary to accomplish the intent of the Stormwater Program. The self-assessment reporting period is the fiscal year (July 1 – June 30). BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Annual Self-Assessment Perform an annual evaluation of Stormwater Management Plan implementation, suitability of Stormwater Management Plan commitments and any proposed changes to the Stormwater Management Plan utilizing the North Carolina Department of Environmental Quality Annual Self- Assessment Template. 1. Prepare, certify and submit the Annual Self- Assessment to North Carolina Department of Environmental Quality prior to August 31 each year. 1. Annually for Permit Years 1 – 4 (FY19/20 – FY22/23) 1. Annual Self- Assessment received by North Carolina Department of Environmental Quality no later than August 31 each year. Permit Ref. 1.6: Permit Renewal Application Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System permit. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 2 Permit Renewal Application NCS000434 SWMP City of Archdale March 5, 2020 Page 14 Table 11: Program Administration Best Management Practices Audit stormwater program implementation for compliance with the permit and approved Stormwater Management Plan, and utilize the results to prepare and submit a permit renewal application package. 1. Participate in an National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System Permit Compliance Audit, as scheduled and performed by Environmental Protection Agency or North Carolina Department of Environmental Quality. 1. To Be Determined – Typically Permit Year 4 1. N/A 2. Self-audit and document any stormwater program components not audited by Environmental Protection Agency or North Carolina Department of Environmental Quality utilizing the Department of Environmental Quality Audit Template. 2. Permit Year 5 2. Submit Self-Audit to Division of Energy, Mineral and Land Resources (required component of permit renewal application package). 3. Certify and submit the stormwater permit renewal application (NOI, Self-Audit, and Draft SWMP for the next 5-year permit cycle). 3. Permit Year 5 3. Permit renewal application package received by Department of Environmental Quality at least 180 days prior to permit expiration. NCS000434 SWMP City of Archdale March 5, 2020 Page 15 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM The City of Archdale will implement a Public Education and Outreach Program to distribute educational materials to the community or conduct equivalent outreach activities about the impacts of storm water discharges on water bodies and steps the public can take to reduce pollutants in storm water runoff. The target audiences and identified pollutants listed in Part 3.9 of this Stormwater Management Plan, which will be addressed by the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the City of Archdale is required to inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping and improper disposal of waste. Table 12: Summary of Target Pollutants & Audiences Target Pollutants/Sources Target Audience(s) See Website for Pollutant General Public, Businesses, Municipal Employees The City of Archdale will manage, implement and report the following public education and outreach BMPs. Table 13: Public Education and Outreach Best Management Practices Permit Ref. 3.2.2 and 3.2.4: Outreach to Targeted Audiences Measures to identify the specific elements and implementation of a Public Education and Outreach Program to share educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The permittee shall provide educational information to identified target audiences on pollutants/sources identified in table 12 above, and shall document the extent of exposure of each media, event or activity, including those elements implemented locally or through a cooperative agreement. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Continue one on one discussion with individuals. Continue one on one discussion with individuals throughout the City of Archdale Statistics as documented through website portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout. Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. NCS000434 SWMP City of Archdale March 5, 2020 Page 16 Table 13: Public Education and Outreach Best Management Practices Permit Ref. 2.1.7, 3.2.3 and 3.6.5(c): Web Site Measures to provide a web site designed to convey the program’s message(s) and provide online materials including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit and SWMP. The web page shall also provide developers with all relevant post-construction requirements, design standards, checklists and/or other materials. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Continue one on one discussion with individuals. Continue one on one discussion with individuals throughout the City of Archdale Statistics as documented through website portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. Permit Ref. 3.2.5: Stormwater Hotline Measures for a stormwater hotline/helpline for the purpose of public education and outreach. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 24/7 Cell Phone (336) 434-7344 Direct Available to all citizens 24/7 Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. NCS000434 SWMP City of Archdale March 5, 2020 Page 17 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM This Stormwater Management Plan identifies the minimum elements and implementation of a Public Involvement and Participation Program that complies with applicable State, Tribal and local public notice requirements. The City of Archdale will manage, implement and report the following public involvement and participation BMPs. Table 14: Public Involvement and Participation Best Management Practices Permit Ref. 3.3.1: Public Input Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Stormwater Advisory Board Auxillary to one on one contact with citizens of Archdale Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. Permit Ref. 3.3.2: Volunteer Opportunities Measures to provide volunteer opportunities designed to promote ongoing citizen participation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Annual Litter Sweep Continue fostering involvement for annual liter sweep Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. NCS000434 SWMP City of Archdale March 5, 2020 Page 18 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The MS4name will develop, manage, implement, document, report and enforce an Illicit Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs. Table 15: Illicit Discharge Detection and Elimination Best Management Practices Permit Ref. 3.4.1: MS4 Map Measures to develop, update and maintain a municipal storm sewer system map including stormwater conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Update photographs of locations as needed through web portal Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. Permit Ref. 3.4.2: Regulatory Mechanism Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4, including enforcement procedures and actions. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. NCS000434 SWMP City of Archdale March 5, 2020 Page 19 Table 15: Illicit Discharge Detection and Elimination Best Management Practices Permit Ref. 3.4.3: IDDE Plan Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4. The plan shall provide standard procedures and documentation to: a) Locate priority areas likely to have illicit discharges, b) Conduct routine dry weather outfall inspections, c) Identify illicit discharges and trace sources, d) Eliminate the source(s) of an illicit discharge, and e) Evaluate and assess the IDDE Program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. Permit Ref. 3.4.4: IDDE Tracking Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was observed, the results of the investigation, any follow-up of the investigation, the date the investigation was closed, the issuance of enforcement actions, and the ability to identify chronic violators. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 5. 5. 5. Permit Ref. 3.4.5: Staff IDDE Training Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities, may observe an illicit discharge, illicit connection, illegal dumping or spills. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping and spills. Each staff training event shall be documented, including the agenda/materials, date, and number of staff participating. A B C D NCS000434 SWMP City of Archdale March 5, 2020 Page 20 Table 15: Illicit Discharge Detection and Elimination Best Management Practices BMP No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. Permit Ref. 3.4.6: IDDE Reporting Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained personnel. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout NCS000434 SWMP City of Archdale March 5, 2020 Page 21 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153, the MS4name relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 and the NCG010000 permit for construction activities as qualifying alternative programs to meet the NPDES MS4 Permit requirements for all construction site runoff control measures to reduce pollutants in stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre and any construction activity that is part of a larger common plan of development that would disturb one acre or more. Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Permit Reference State or Local Program Name Legal Authority Implementing Entity Meets Whole or Part of Requirement 3.5.1 - 3.5.4 City of Archdale Delegated SPCA Program* 15A NCAC Chapter 04 City of Archdale Whole 3.5.1 - 3.5.4 State Implemented SPCA Program 15A NCAC Chapter 04 North Carolina Department of Environmental Quality Whole 2 * The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at: City of Archdale Code of Ordinances The City of Archdale also implements the following Best Management Practices to meet National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System Permit requirements. Table 17: Construction Site Runoff Control BMPs Permit Ref. 3.5.6: Public Input Measures to provide and promote a means for the public to notify the appropriate authorities of observed erosion and sedimentation problems. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Municipal Staff Training Train municipal staff who receive calls from the public on the protocols for referral and tracking of construction site runoff control complaints. 1. Train municipal staff on proper handling of construction site runoff control complaints. 1. Annually beginning in Permit Year 1 (FY19/20) 1. Document and report number of staff trained, training date(s) and topics covered. 2. 2. 2. 3. 3. 3. 4. 4. 4. NCS000434 SWMP City of Archdale March 5, 2020 Page 22 Table 17: Construction Site Runoff Control BMPs 5. 5. 5. Permit Ref. 3.5.5: Waste Management Measures to require construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to water quality. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction by field supervisors Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout NCS000434 SWMP City of Archdale March 5, 2020 Page 23 PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM This Stormwater Management Plan identifies the minimum elements to develop, implement and enforce a program to address stormwater runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that are located within the City of Archdale and discharge into the Municipal Separate Storm Sewer System. These elements are designed to minimize water quality impacts utilizing a combination of structural Stormwater Control Measures (SCMs) and/or non-structural Best Management Practices appropriate for the community, and ensure adequate long-term operation and maintenance of Stormwater Control Measures. In accordance with 15A NCAC 02H .0153 and .1017, the MS4name implements the following State post- construction program requirements, which satisfy the NPDES Phase II MS4 post-construction site runoff control requirements as Qualifying Alternative Programs (QAPs) in the MS4 area(s) where they are implemented. Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program Not Applicable State QAP Name State Requirements Local Ordinance / Regulatory Mechanism Reference None N/A N/A Water Supply Watershed (WS-I) 15A NCAC 2B .0620 - .0624 Water Supply Watershed (WS-II) 15A NCAC 2B .0620 - .0624 Water Supply Watershed (WS-III) 15A NCAC 2B .0620 - .0624 Water Supply Watershed (WS-IV) 15A NCAC 2B .0620 - .0624 Neuse River Basin Nutrient Sensitive (NSW) Management Strategy 15A NCAC 2B .0235 Tar-Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy 15A NCAC 2B .0258 Randleman Lake Water Supply Watershed Nutrient Management Strategy 15A NCAC 2B .0251 Universal Stormwater Management Program 15A NCAC 2H .1020 NCS000434 SWMP City of Archdale March 5, 2020 Page 24 2 See Watershed Map The City of Archdale has existing requirements other than Qualifying Alternative Program(s) for implementation of the NPDES Phase II Municipal Separate Storm Sewer System post-construction program requirements. These existing requirements are codified in local ordinance(s), and implementation is further defined in guidance, manuals and/or standard operating procedure(s) as summarized in Table 19 below. Table 19: Summary of Existing Post-Construction Program Elements NCS000434 SWMP City of Archdale March 5, 2020 Page 25 Permit Requirements for Plan Review and Approval Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.2(a) Authority ACE Integrated Stormwater Management Program January 2, 2008 3.6.3(a) & 15A NCAC 02H.0153(c) Federal, State & Local Projects ACE Integrated Stormwater Management Program January 2, 2008 3.6.3(b) Plan Review ACE Integrated Stormwater Management Program January 2, 2008 3.6.3(c) O&M Agreement ACE Integrated Stormwater Management Program January 2, 2008 3.6.3(d) O&M Plan ACE Integrated Stormwater Management Program January 2, 2008 3.6.3(e) Deed Restrictions/Covenants ACE Integrated Stormwater Management Program January 2, 2008 3.6.3(f) Access Easements ACE Integrated Stormwater Management Program January 2, 2008 Permit Requirements for Inspections and Enforcement Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.2(b) Documentation ACE Integrated Stormwater Management Program January 2, 2008 3.6.2(c) Right of Entry ACE Integrated Stormwater Management Program January 2, 2008 3.6.4(a) Pre-CO Inspections ACE Integrated Stormwater Management Program January 2, 2008 3.6.4(b) Compliance with Plans ACE Integrated Stormwater Management Program January 2, 2008 3.6.4(c) Annual SCM Inspections ACE Integrated Stormwater Management Program January 2, 2008 3.6.4(d) Low Density Inspections ACE Integrated Stormwater Management Program January 2, 2008 3.6.4(e) Qualified Professional ACE Integrated Stormwater Management Program January 2, 2008 Permit Requirements for Fecal Coliform Reduction Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.6(a) Pet Waste ACE Integrated Stormwater Management Program January 2, 2008 3.6.6(b) On-Site Domestic WastewaterTtreatment Not Applicable Not Applicable NCS000434 SWMP City of Archdale March 5, 2020 Page 26 The annual reporting metrics for the post construction program are provided in Table 20: Post Construction Site Runoff Control BMPs below. Table 20: Post Construction Site Runoff Control BMPs Permit Ref. 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post-Construction Reporting Requirements Measures to document activities over the course of the fiscal year (July 1 – June 30) including appropriate information to accurately describe progress, status, and results. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #. Standard Reporting Implement standardized tracking, documentation, inspections and reporting mechanisms to compile appropriate data for the annual self- assessment process. Data shall be provided for each Post-Construction/ Qualifying Alternative Program being implemented as listed in Tables 18 and 19. 1. Track number of low density and high density plan reviews performed. 1. Continuously 1. Number of plan reviews performed for low density and high density. 2. Track number of low density and high density plans approved. 2. Continuously 2. Number of plan approvals issued for low density and high density. 3. Maintain a current inventory of low density projects and constructed SCMs including SCM type or low density acreage, location and last inspection date. 3. Continuously 3. Summary of number and type of SCMs added to the inventory; and number and acreage of low density projects constructed. 4. Track number of SCM inspections performed. 4. Continuously 4. Number of SCM inspections. 5. Track number of low density inspections performed. 5. Continuously 5. Number of low density inspections. 6. Track number and type of enforcement actions taken. 6. Continuously 6. Number and type of enforcement actions taken. Permit Ref. 2.3 and 3.6: Qualifying Alternative Program(s) Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state program requirements. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Not Used 1. 1. 1. 2. 2. 2. 3. 3. 3. NCS000434 SWMP City of Archdale March 5, 2020 Page 27 Table 20: Post Construction Site Runoff Control BMPs Permit Ref. 3.6.2: Legal Authority Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review designs and proposals for new development and redevelopment to determine whether adequate stormwater control measures will be installed, implemented, and maintained, (b) request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post-Construction Stormwater Management Program, and (c) enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater discharges to determine whether there is compliance with the Post-Construction Stormwater Management Program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Technical Review Committee, as required Review all Zoning Permits 1) <10,000; 10,000 < X < 1 Acre; > 1 acre Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout Permit Ref. 3.6.3: Plan Review and Approval Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal, State, and local government projects to comply with Post-Construction Program requirements throughout the entire Municipal Separate Storm Sewer System permitted area, unless the entity is subject to its own National Pollutant Discharge Elimination System permit or a qualifying alternative program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that complies with 15A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A NCAC 02H 1050 (9) and (10). BMP No. A B C D Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout NCS000434 SWMP City of Archdale March 5, 2020 Page 28 Table 20: Post Construction Site Runoff Control BMPs Permit Ref. 3.6.4: Inspections and Enforcement Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post- construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy. Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s), (b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require that inspections be conducted by a qualified professional. BMP No. A B C D Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout Permit Ref. 3.6.6: Fecal Coliform Reduction Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H .1017(7). At a minimum, the program shall include: (a) A pet waste management component, which may be achieved by revising an existing litter ordinance, and (b) An on-site domestic wastewater treatment system component, if applicable, which may be coordinated with local county health department, to ensure proper operation and maintenance of such systems. BMP No. A B C D Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout NCS000434 SWMP City of Archdale March 5, 2020 Page 29 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the MS4name municipal facilities and operations. Pollution prevention and good housekeeping is accomplished through the implementation of seven required programs, which collectively address the ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and open space maintenance, fleet and building maintenance, new construction and land disturbances, and municipal storm sewer system maintenance. Pollution prevention and good housekeeping for municipal operations includes the following programs: 1. Municipal Facilities Operation and Maintenance Program 2. Spill Response Program 3. Municipal Separate Storm Sewer System Operation and Maintenance Program 4. Municipal Stormwater Control Measures Operation and Maintenance Program 5. Pesticide, Herbicide and Fertilizer Management Program 6. Vehicle and Equipment Maintenance Program 7. Pavement Management Program The City of Archdale will manage, implement and report the pollution prevention and good housekeeping BMPs as specified in Table 21 below for each required program. Table 21: Pollution Prevention and Good Housekeeping Best Management Practices Permit Ref. 3.7.1: Municipal Facilities Operation and Maintenance Program Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities; perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on general stormwater awareness and implementing pollution prevention and good housekeeping practices. BMP No. A B C D Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout 5. 5. 5. Permit Ref. 3.7.2: Spill Response Program Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response procedures. A B C D NCS000434 SWMP City of Archdale March 5, 2020 Page 30 Table 21: Pollution Prevention and Good Housekeeping Best Management Practices BMP No. Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout Permit Ref. 3.7.3: MS4 Operation and Maintenance Program Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections, maintain the collection system including catch basins and conveyances; and establish specific frequencies, schedules, and standard documentation. BMP No. A B C D Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout Permit Ref. 3.7.4: Municipal SCM Operation and Maintenance Program Measures to manage municipally-owned, operated, and/or maintained structural SCMs that are installed for compliance with the permittee’s post-construction program. The permittee shall maintain a current inventory of SCMs, perform SCM inspections and maintenance, and shall establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout Permit Ref. 3.7.5: Pesticide, Herbicide and Fertilizer Management Program Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine pollution prevention and chemical use, storage and handling training, and shall ensure compliance with permits and applicator certifications. BMP No. A B C D Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout NCS000434 SWMP City of Archdale March 5, 2020 Page 31 Table 21: Pollution Prevention and Good Housekeeping Best Management Practices Permit Ref. 3.7.6: Vehicle and Equipment Maintenance Program Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout Permit Ref. 3.7.7: Pavement Management Program Measures to reduce pollutants in stormwater runoff from municipally-owned streets, roads, and parking lots within the permittee’s corporate limits. The permittee shall implement measures to control litter, leaves, debris, particulate and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of Best Management Practice Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1 Continue to update locations as needed through web portal and involvement interaction Continue fostering web portal interaction. Statistics tracked through web portal and Microsoft Outlook Website portal initial training following June 28, 2020 rollout Report through comments at closeout