HomeMy WebLinkAboutNCS000542_Henderson Draft SWMP v2_20210209City of Henderson
Engineering Department
900 S. Beckford Drive
P.O. Box 1434
Henderson, North Carolina 27536
252.430.5728
Fax 252.492.7935
www.ci.henderson.nc.us
LETTER OF TRANSMITTAL
DATE: Monday, February 08, 2021
TO: NCDEQ
512 N Salisbury St
Raleigh, NC 27604
REFERENCE:
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Description
Draft SW Mgmt Plan City of Henderson NCS000542
Z� 0S -eioz r
Signed By: Date:
Received By:
uate:
Draft Stormwater Management Plan
City of Henderson
NCS000542
January 28, 2021
A.:
RECEIVE
FEB 0 9 2021
DENR-LAND QUALITY
STORMWATER PERMITTING
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Stormwater Management Plan
Table of Contents
Part1: INTRODUCTION..........................................................................................................................1
Part2: CERTIFICATION.........................................................................................................................2
Part3: MS4 INFORMATION...................................................................................................................3
3.1
Permitted MS4 Area.........................................................................................................3
3.2
Existing MS4 Mapping.....................................................................................................4
3.3
Receiving Waters..............................................................................................................6
3.4
MS4 Interconnection........................................................................................................7
3.5
Total Maximum Daily Loads (TMDLs)...........................................................................7
3.6
Endangered and Threatened Species and Critical Habitat................................................8
3.7
Industrial Facility Discharges...........................................................................................8
3.8
Non-Stormwater Discharges.............................................................................................9
3.9
Target Pollutants and Sources........................................................................................10
Part 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION................................12
4.1 Organizational Structure.................................................................................................12
4.2 Program Funding and Budget.........................................................................................13
4.3 Shared Responsibility.....................................................................................................15
4.4 Co-Permittees.................................................................................................................15
4.5 Table 10: Co-Permittee Contact Information................................................................15
4.6 Measurable Goals for Program Administration..............................................................15
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM.....................................................17
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM.....................................21
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM ......................23
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM.............................................27
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM..................................29
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS...............33
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page
Stormwater Management Plan
List of Tables
Table1:
Summary of MS4 Mapping....................................................................................................................... 5
Table 2A:
Summary MS4 Receiving Waters — Roanoke River Basin........................................................................6
Table 213:
Summary MS4 Receiving Waters — Tar -Pamlico River Basin..................................................................6
Table 3:
Summary of Approved TMDLs.................................................................................................................
7
Table 4:
Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality .................................
8
Table 5:
NPDES Stormwater Permitted Industrial Facilities...................................................................................9
t
Table 6:
Non-Stormwater Discharges......................................................................................................................9
Table 7:
Summary of Target Pollutants and Sources.............................................................................................11
Table 8:
Summary of Responsible Parties.............................................................................................................13
Table 9:
Shared Responsibilities............................................................................................................................15
Table 12:
Summary of Target Pollutants & Audiences...........................................................................................17
Table 16:
Qualifying Alternative Program Components for Construction Site Runoff Control Program ...............27
- Table 18:
Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program ........................29
Table 19:
Summary of Existing Post -Construction Program Elements...................................................................29
Table 20:
Post Construction Site Runoff Control BMPs.........................................................................................30
Table 21:
Pollution Prevention and Good Housekeeping BMPs.............................................................................
33
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page ii
Stormwater Management Plan
Part 1: INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which
the City of Henderson 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 Henderson 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 MS4 Permit number NCS000542, as issued by NCDEQ. This permit covers activities associated with
- the discharge of stormwater from the MS4 as owned and operated by the City of Henderson and located
within the corporate limits of the City of Henderson.
In preparing this SWMP, the City of Henderson has evaluated its MS4 and the permit requirements to
develop a comprehensive 5-year SWMP that will meet the community's needs, address local water
quality issues and provide the minimum measures necessary to comply with the permit. The SWMP 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 SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along
with any approved modifications of the SWMP, are incorporated by reference into the permit and become
enforceable parts of the permit.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 1
IStormwater Management Plan
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
l persons who manage the system, or those persons directly responsible for gathering the information, the
l 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 NPDES MS4
Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit
compliance and enforcement authority.
® I am a ranking elected official.
❑ I am a principal executive officer for the permitted MS4.
❑ I am a duly authorized representative for the permitted MS4 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: Eddie Ellington
Title: Mayor
Signed this y ?J' _ da of 20
r
L
j DRAFT NCS000542 SWMP
V City of Henderson
February 5, 2021
r Page 2
IStormwater Management Plan
IPart 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This SWMP applies throughout the corporate limits of the City of Henderson, including all regulated
activities associated with the discharge of stormwater from the MS4. The map below shows the corporate
limits of City of Henderson as of the date of this document. Please note that the corporate city limits are
defined per ordinance but sometimes the city limit line splits parcel lines, these splits occur due to plat
subdivision or recombination. The extra -territorial jurisdiction (ETJ), depicted in green, is an arbitrary
boundary defined as 1 mile from the city limits line, and this boundary has been plagued with split
parcels. However, City of Henderson staff have worked hard to reduce the number of splits to provide
consistent protections for county residents, while trying to limit the negative impacts of city regulations
( where a small split may create a burden.
I DRAFT NCS000542 SWMP
L City of Henderson
February 5, 2021
Page 3
Stormwater Management Plan
3.2 Existing MS4 Mapping
The City of Henderson's Engineering Department is in the process of updating the current MS4 map,
which will include the location of stormwater inlets, pipes, junction boxes, stormwater control measures
(SCMs) and Outfalls. Ienderson's mapping to date has not included ditches from an asset inventory
standpoint but, they are delineated on our base maps by knowing how to interpret contour lines. As the
E , city of Henderson's MS4 program matures we will map the streams and ditches to include the condition
(physical and water quality) and morphology.
The City of Raleigh's stormwater department supported the City of Henderson stormwater system
mapping effort by sharing their knowledge, experiences and nomenclature. While this collaboration was
fantastic in getting our mapping program up and going, it was overwhelming due to the limited staff we
had and the extent of work Raleigh had put into their system. Therefore, the City of Henderson had to
limit the scope of what Raleigh has done but with the intent of collecting the majority of the pertinent
data. The City of Henderson hired 2 part-time interns over the last two years to collect the data Our
interns were trained to use GPS equipment (Arrow Gold) and ESRI Collector on an Apple iPad. Initially,
the data collected was labor-intensive due to the amount of post processing and the re-training that was
required due to the GIS technician attrition. The current GIS Technician was able to develop a script to
batch process the points and significantly reduce the amount of post processing, eventually in late 2019
the GPS software was improved and the point data was processed/corrected during collection. The GPS
equipment on the market today is attainable at a price point and the accuracy has significantly improved
so that most of our data has a 1-cm accuracy.
The City of Henderson's Engineering department has collected the stormwater data in GIS and then
pushed this data over to an asset inventory system (Cartegraph) so our Public Works (PW) Department
can perform work against these assets. The PW crews are currently working with the Engineering
Department to correct the stormwater maps. During the collection of data, the GIS interns were instructed
NOT to remove inlet covers or physically enter these structures due to safety issues and confined space
concerns. These restraints on the data collection hampered the intern's ability to determine pipe size,
invert depth, condition assessment and flow direction. While the stormwater system map is approximately
90% mapped there are inaccuracies in the data which are being improved on an on -going basis. One of
the more difficult legal issues to address with respect to mapping is distinguishing where private and
public system start and stop (i.e. a strip mall may build and attach to Henderson's public collection
system route the upstream flow through their private collection system then discharge back into a public
collection system). This brings up questions of construction standards, beneficial use, maintenance and
operations and future improvements.
Please note that the City of Henderson does not have a public facing map to any of our systems (water,
sewer, roads and stormwater). The City of Henderson does not want developers making engineering
decisions based on a map that may contain errors. We require all developers to contact engineering about
their plans then the City of Henderson reviews these plans and ground truths to verify if the system can
accommodate the additional capacity.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
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Stormwater Management Plan
•
C
MLegend•' �� �
Roads Storm -stream a Storm nIe, .,. ,
:ram.
City of Henderson — Storm Water Map (Redline is the City Limits)
Table 1: Summary of MS4 Mapping
Percent of MS4 Area Mapped
90
%
No. of Major Outfalls* Mapped
Unknown**
total
* An ou fall is a point where the MS4 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.
** Receiving streams and their tributaries have been identified as well as the sub -basins. The City of
Henderson needs to evaluate the drainage basin with respect to NCDEQ guidance to identify and
classify the outfalls. In many cases, a stream may receive multiple discharges within a short reach
and if this meets the acreage requirement then the City of Henderson has noted this as an Outfall.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
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E Stormwater Management Plan
3.3 Receiving Waters
r__. The City of Henderson MS4 is located within the Tar-Pamilco and Roanoke River Basins and discharges
directly into receiving waters as listed in Table 2A and 2B below. Applicable water quality standards
listed below are compiled from the following NCDEQ sources:
o Waterbody Classification Map
o Impaired Waters and TMDL Map
o Most recent NCDEQ Final 303(d) List
Table 2A: Summary MS4 Receiving Waters — Roanoke River Basin
Stream
Water
FReceiving;Water
Index / AU
Quality
303(d) Listed
,Name
Stream Segment
Number
Classification
Parameter(s)
Benthos (Nar,
Nutbush Creek
From source to Crooked Run
23-8-(1)
C
AL
' FW)
Fish Community
(Nar, AL, FW)
UT to Crooked Run
i
From source to Crooked Run
23-8-3
B
N/A
j
From source to Nutbush Creek
, Crooked Run
Arm of John B. Kerr
23-8-3
B
N/A
i
Reservoir
1
From source to Carolina
Indian Creek
Power & Light Company
23-8-4-(1)
C
N/A
Power Line
Table 2B: Summary MS4 Receiving Waters — Tar -Pamlico River Basin
Water
Receiving Stream
Index AU
Quality
303(d) Listed
Name
Stream Segment
Number
Classification
Parameter
Ruin Creek
From dam to Tabbs Creek
28-17-2-(2)
C; NSW
N/A
Red Bud Creek
From source to Ruin Creek
28-17-2-3
C: NSW
N/A
UT to Ruin Creek
From source to Ruin Creek
28-17-2-(2)
C: NSW
N/A
Branch
From source to Ruin Creek
28-17-2-4
___]Joes
C; NSW
N/A
Sandy Creek
From source to dam at
28-78-1-(1)
C.NSW; +
N/A
Southerlands Pond
i
Martin Creek
From source to Sandy Creek
28-78-1-3
C; NSW; +
N/A 1
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 6
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_ Stormwater Management Plan
3.4 MS4 Interconnection
The City of Henderson MS4 is not interconnected with another regulated MS4 and directly discharges to
the receiving waters as listed in Tables 2A and 2B above.
3.5 Total Maximum Daily Loads (TMDLs)
The TMDL(s) listed in Table 3 below have been approved within the MS4 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
Stormwater Water iQuality
Waste Load' Recovery
AllocationProgram
Water Body Name TMDL Pollutant(s) of Concern (Y/N) (Y/N)
Total Nitrogen (1.361_e6 Kg/Yr) N N
Tar River
Total Phosphorus (0.18 e6 Kg/Yr) N N
The City of Henderson recognizes that the Environmental Protection Agency in conjunction with the
North Carolina Department of Environmental Quality has done tremendous work with respect to hypoxia
problems in the lower water column of Pamlico Estuary as well as a thorough review of the factors
leading to this oxygen depletion. The promulgation of the Nutrient Sensitive Waters and the associated
Best Management Practices (BMPs) now known as Stormwater Control Measures (SCMs) have made
positive strides towards reducing the negative impacts of development on downstream water bodies. But
even with these positive steps forward there is so much more that can be done and NCDEQ has
recognized and identified 6 measures to improve stormwater quality which includes; education, citizen
participation, illicit discharge enforcement, construction runoff, post construction runoff and pollution
prevention and good house -keeping at municipal operations.
EPA/DEQ's report identified Total Nitrogen (TN) and Total Phosphorus (TP) as primary constituents of
interest to reduce the oxygen depletion. The NSW regulations have placed discharge limits from SCMs on
both these constituents as well as providing the efficiencies of removal for these constituents by the
SCMs. Currently the TN discharge limit is set at 4.0 lbs/acre/year and TP is set at 0.4 lbs/acre/year from a
new development site and a 30% reduction in TN from existing sites. Henderson's City Engineer reviews
_ all plans and calculations for compliance to the NSW regulations. New developments and their associated
SCMs work closely with the City and Morgensen Mitigation Bank so the developer can purchase nutrient
credits and come into compliance with the tools provided by NCDEQ.
Henderson's City Council has received the stormwater Notice of Violation in June 2020 and adopted a
Resolution (No. 20-50) in August 2020 to not only implement the measure outlined in NCDEQ's MS4
Stormwater Program but also to fund the implementation of this program. Engineering Staff has worked
tirelessly to map all the impervious surfaces in the City with the exception of single-family dwellings.
Staff presented a recommendation to council to hire a consultant to assist us in the development and
implementation of a stormwater utility. Council awarded the Stormwater Utility setup to Dewberry
Engineers and they have developed the documents necessary to implement a Stormwater utility. As of the
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 7
l . Stormwater Management Plan
writing of this report, council action has not moved forward with respect to a Stormwater Utility but, the
new City Manager has slated this important funding stream on his agenda matrix. Stormwater quality and
MS4 compliance for the City of Henderson requires funding of two full time positions, collaboration with
Public Works and the hiring of part-time staff to assist in field data collection and reconciliation by GIS
staff.
C Henderson's Engineering Staff includes an engineering inspector that is certified for BMP construction
and maintenance and this individual has mapped and commented on the condition of existing SCMs
(BMPs) within the City Limits. The engineering inspector is also involved in the inspection and
construction of sedimentation and erosion control measure for which he generates weekly reports during
construction as well as the conversion of sedimentation devices to SCMs once the ground is stabilized.
The engineering inspector and city engineer talk throughout the project to make sure everything is
working smoothly so, by the time the final inspection takes place the revisions are very small. At the final
walk through the contractor, engineer of record, city engineer and engineering inspector draw up a final
punch list to get the site and all its components into compliance. This is a critical step in how the SCM
will perform and any additional modifications prior to the final approval.
Funding is a critical component in Henderson's stormwater program because it not only allows us to hire
staff but provides training, tools, money for capital improvement projects, hiring consultants with the
expertise to help Henderson develop and hone specific aspects of the program.
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 MS4 urbanized area, as determined by a review of the Endangered and Threatened
Species and Species of Concern by 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 Grou
Federal
Listing Status
Haliaeetus leucocephalus
Bald Eagle
Vertebrate
BGPA
Noturus furiosus
Carolina Madtom
Vertebrate
ARS
Necturus lewisi
Neuse River Waterdog
Vertebrate
ARS
Fusconaia masoni
Alantic Pigtoe
Invertebrate
ARS
Alasmidonta heterodon
Dwarf Wedgemussel
Invertebrate
E
Parvaspina steinstansana
Tar River spinymussel
Invertebrate
E
Elliptio lanceolata
Yellow Lance
Invertebrate
T
3.7 Industrial Facility Discharges
The City of Henderson MS4 jurisdictional area includes the following industrial facilities which hold
NPDES Industrial Stormwater Permits, as determined from the NCDEQ Active NPDES Stormwater
Permit List and/or Active Stormwater Permits Map.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 8
Stormwater Management Plan
Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number
Facility Name
NCGNE0460
Timberline Acquisition, LLC
NCG050393
Vescom
NCG210331
Idaho Timber of North Carolina LLC
NCG080713
Henderson Operations & Service Center
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the City of Henderson as
summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not
significantly impact water quality. The City of Henderson has evaluated residential car washing for
possible significant water quality impacts.
Street washing discharges are addressed under the Pavement Management Program in Part 10 of this
SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the
City of Henderson. The City performs street sweeping on curb and gutter streets; however, no street
washing is conducted. A small amount of water is used in the street sweeping activity on the order of
150 gallons per mile or 0.027 gallons/foot. The vast majority of the water used in the street sweeping
operation is bound to the refuse and vacuumed up into the dump bed on the sweeper truck. Approximately
1,000 pounds of refuse is collected per mile and discharged at the landfill.
Wash water associated with car washing that does not contain detergents or does not discharge directly
into the MS4 is considered incidental. However, these types of non-stormwater discharges that do contain
detergents have been evaluated by the City of Henderson to determine whether they may significantly
impact water quality. The City has an unusually high number of commercial car washes compared to the
population for most municipalities therefore, it is unusual to see residential car washing occurring and
rarely does it spill into the street or stormwater system. The discharges directly from residential home and
car washing into the MS4 is considered a possible source of impact to water quality. The City of
Henderson shall make a concerted effort via public education about the use of detergents and cleaners
used in the washing of cars and homes as well as their possible water quality impacts.
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
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 9
Stormwater Management Plan
Table 7: Summary of Target Pollutants and Sources
Likely Sources)/Target
SWMP Program Addressing
Target Pollutants
Audiences
Target Pollutant(s)/ Audience(s)
Litter
Citizens on daily commute
Public Education & Outreach
Sediment & Erosion Control
Delegated Authority: Henderson's
Engineering Department addresses
this issue from a delegated authority
and permit compliance approach for
Historical Developers lacked
larger developments. Single family
attention to sediment transport.
homes are discovered via planning
Sediment
Current Residential and
or site drive-by(s).
Commercial Construction
Collaboration with the County
building inspection department
Notification of new building
permits. The certificate of
occupancy is an ultimate compliance
trigger that we use for commercial
compliance.
Fecal coliform
Sewer overflows, failing septic
Public Education & Outreach, Illicit
systems, wildlife, illicit discharges
Discharge Detection & Elimination
Illicit discharges
Residential, commercial, industrial,
Public Education & Outreach, Illicit
municipal staff
Discharge Detection & Elimination
Illegal dumping
Residential, commercial, industrial,
Public Education & Outreach, Illicit
municipal staff
Discharge Detection & Elimination
General non -point source
Residential, commercial, schools,
Public Education & Outreach
pollution
municipal staff
Nitrogen and phosphorus
Residential, commercial, industrial,
Public Education & Outreach
municipal staff
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 11
1 . Stormwater Management Plan
I
Part 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure
The City of Henderson is governed as a City Council — Manager form of government where City Council
has 3 employees: City Manager, City Clerk and City Attorney. All City Staff fall under the
Administrative responsibility of the City Manager. The City's organizational structure is shown below
where key department heads and their assistant department heads are noted:
L.
M-B.'�
Finance Police Chief assistantChief
Joey Fuqua Marcus Barrow Vance Johnson
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
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Stormwater Management Plan
Table 8: Summary of Responsible Parties
SWMP Component
ResponsiblePosition
Staff Name
Department
Stormwater Program
Administration
City Engineer
Mr. Clark Thomas
Engineering
SWMP Management
City Engineer
Mr. Clark Thomas
Engineering
Public Education &
Outreach
City Engineer
Mr. Clark Thomas
Engineering
Public Involvement &
Participation
City Engineer
Mr. Clark Thomas
Engineering
Illicit Discharge Detection
& Elimination
City Engineer
Mr. Clark Thomas
Engineering
Construction Site Runoff
City Engineer
Mr. Clark Thomas
Engineering
Control
Engineering Inspector
Mr. Dale Jones
Engineering
Post -Construction
Stormwater Management
City Engineer
Mr. Clark Thomas
Engineering
Pollution Prevention/Good
Housekeeping for Municipal
Public Works Director
Mr. Andy Perkinson
Public Works Dept.
Operations
Municipal Facilities
Operation & Maintenance
Public Works Director
Mr. Andy Perkinson
Public Works Dept.
Program
Spill Response Program
City Engineer
Mr. Clark Thomas
Engineering
MS4 Operation &
Maintenance Program
City Engineer
Mr. Clark Thomas
Engineering
Municipal SCM Operation
& Maintenance Program
City Engineer
Mr. Clark Thomas
Engineering
Pesticide, Herbicide &
Public Works Director
Mr. Andy Perkinson
Fertilizer Management
Asst. Public Works
Mr. Lee Owen
Public Works Dept.
Program
Director
Vehicle & Equipment
Public Works Director
Mr. Andy Perkinson
public Works Dept.
Cleaning Program
Garage Supervisor
Mr. Charles Poteat
Pavement Management
Program
Public Works Director
Mr. Andy Perkinson
Public Works Dept.
Total Maximum Daily Load
N/A
N/A
N/A
(TMDL) Requirements
4.2 Program Funding and Budget
In accordance with the issued permit, the City of Henderson is required to maintain adequate funding and
staffing to implement and manage the provisions of the SWMP and comply with the requirements of the
NPDES MS4 Permit. The budget includes the permit administering and compliance fee, which is billed
by the Division annually. However, the program is underfunded with respect to compliance with the six
program elements, also referred to as minimum control measures.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 13
Stormwater Management Plan
The stormwater program currently receives funding of approximately $25,000 per year for emergency
repairs and is funded primarily through the General Funds (Street Division). The street division has a
street sweeper and a jet -vac to clean the streets and stormwater pipes when they get clogged. The City
utilizes a work order system to help department heads schedule their work and assess the quality and costs
of each repair. Cartegraph is the name of the work order/asset management system and it has a component
to assign preventative maintenance for specific assets. The City's public works departments plans to
implement a program to clean at least 10% of the storm drains each year. The stormwater program will be
E developed in the next year to mirror the existing sanitary sewer preventative maintenance program.
Currently public works dedicates 65 manhours a week to addressing the stormwater infrastructure. As the
stormwater program expands; the duties, responsibilities and manhours in the street department will
increase accordingly.
The administration of the city's stormwater regulatory side is performed by the City Engineer,
Construction Inspector and Engineering Technician which are funded through the Water Fund. In total the
stormwater program receives 5-6 hours a week from the engineering staff. The City of Henderson has
experienced only a small uptick in development over the last 7 years. Therefore, stormwater SCM review
and inspection is only a small component of the department's workload.
Through the gap analysis, self -evaluation process and NCDEQ audit; it is evident that the City of
Henderson needs to fund a minimum of two full time position equivalents (FTE) which includes at least
two part-time positions for the stormwater program. The key position is a stormwater engineer to head -up
the program along with an administrative assistant (30%) and the City Engineer (20%) to guide and
promote the program with the community and City Council. The part-time positions are critical in data
- collection, mapping and assessment.
The City has performed an analysis to create a stormwater utility. The funding arm proposed for this
utility is based on a flat rate for residential (single and duplex occupancies) units. Fees for multi -family,
industrial and commercial zoning is based on acreage of impervious area. Due to the nature of several
large businesses, the analysis showed that 13 businesses in the city would carry 65% of the Utility's fee.
Henderson is an old textile town that is still reeling from the economic downturn created by NAFTA and
to impose a large monthly fee on these legacy businesses has become untenable to several members of the
City Council. Staff has gone back and revised Stormwater Utility Fee structure to impose a minimum and
maximum monthly fee where the maximum charge to an individual business would be $300 and a
$20/month minimum on every business. This minimum and maximum structure reduces the burden to the
large businesses and redistributes these costs on smaller businesses while providing the same revenue
stream as the initial impervious acreage fee to the City.
Additional staff via the stormwater utility will address the fundamental tenants of the stormwater
program. The self -audit that was composed by a consultant in conjunction with Henderson's engineering
staff indicates there are many deficiencies and work to be performed over the coming years. Current
market trends place a trained stormwater engineer in great demand by large and small municipalities as
well as large and small consultants. Henderson along with many other small municipalities without
stormwater utilities can barely afford an Engineering Intern much less a seasoned midlevel engineer with
5-10 years that would not require any training. The City Engineer has for the third year put a stormwater
engineer in the budget along with an administrative assistant and more money for part-time interns. The
City Manager has met with the City Engineer for the Fiscal Year 21-22 and understands the gravity of the
stormwater engineer. The manager also understands the funding mechanism to make this position a
reality.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
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Stormwater Management Plan
4.3 Shared Responsibility
The City of Henderson does not share the responsibility to implement any minimum control measures of
the NPDES MS4 Permit requirement. The City of Henderson is solely responsible for compliance.
Table 9: Shared Responsibilities
SWMP BMP or
Permit Requirement
Implementing Entity & Program Name
Legal Agreement
Y/N
N/A
N/A
N
4.4 Co-Permittees
There are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000542 for the City of Henderson.
4.5 Table 10: Co-Permittee Contact Information
Co` Permittee MS4 Name
Contact Person
Phone & E-Mail
Interlocal Agreement
Y/N
N/A
N/A
N/A
N
4.6 Measurable Goals for Program Administration
The City of Henderson will manage and report the following Best Management Practices (BMPs) for the
administration of the Stormwater Management Program.
Table 11: Program Administration BMPs
Permit
2.1.2 and Part 4: Annual Self -Assessment
Ref.
Measures to evaluate the performance and effectiveness of the SWMP 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).
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
1.
Annual Self -Assessment
Perform an annual evaluation
1. Prepare, certify and
1. Annually for
1. Annual Self -
of SWMP implementation,
submit the Annual
Permit Years 1
Assessment
suitability of SWMP
Self -Assessment to
— 4
received by
commitments and any
NCDEQ prior to
(FYI 9/20 —
NCDEQ no later
proposed changes to the
August 31 each year.
FY22/23)
than August 31
SWMP utilizing the NCDEQ
each year.
Annual Self -Assessment
Template.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 15
__,
Stormwater Management Plan
Table 11: Program Administration BMPs
Permit
1.6: Permit Renewal Application
Ref.
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of
the NPDES MS4 permit.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
2.
Permit Renewal Application
Audit stormwater program
1. Participate in an
1. TBD —Typically
1. N/A
implementation for
NPDES MS4
Permit Year 4
compliance with the permit
Permit Compliance
and approved SWMP, and
Audit, as scheduled
utilize the results to prepare
and performed by
and submit a permit renewal
EPA or NCDEQ.
application package.
2. Self -audit and
2. Permit Year 5
2. Submit Self -
document any
Audit to
stormwater program
DEMLR
components not
(required
audited by EPA or
component of
NCDEQ utilizing
permit renewal
the DEQ Audit
application
Template.
package).
3. Certify and submit
3. Permit Year 5
3. Permit renewal
the stormwater
application
permit renewal
package received
application (NOI,
by DEQ at least
Self -Audit, and
180 days prior to
Draft SWMP for
permit
the next 5-year
expiration.
permit cycle).
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 16
Stormwater Management Plan
I
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The City of Henderson 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 SWMP, which will be addressed by
the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the City of
Henderson 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)
Illicit Discharges
General Public, Businesses, Municipal Employees
Illegal Dumping
General Public, Businesses, Municipal Employees
Improper Disposal of Waste
General Public, Businesses, Municipal Employees
The City of Henderson will manage, implement and report the following public education and outreach
BMPs.
Table 13: Public Education and Outreach BMPs
Permit
32.2 and 3.2.4: Outreach to Targeted Audiences
Ref.
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.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual
Implementation
Reporting Metric
3.
Establish Goals and Objectives
Identify goals and objectives of the
1. Report the
1. Permit Year 4'
1. Y/N/Status
Local Public Education and
identified goals
FY20/21
List goals and
Outreach Program based on
and objectives in
objectives of
community wide issues.
the Annual
the Public
Report.
Education and
Outreach
Program.
4.
Describe Target Pollutants and Target Audiences
' Permit Year numbers identified in Tables 13 through 21 are in reference to the current City of Henderson NPDES
Permit Number NCS000542, effective February 20, 2017 through February 19, 2022. Upon issuance of a new
MS4 Permit in response to the NCDEQ audit, these Permit Years will need to be updated.
DRAFT NCS000542 SWMP
_._ City of Henderson
February 5, 2021
Page 17
Stormwater Management Plan
Table 13: Public Education and Outreach BMPs
Maintain a description of the target
1. Maintain
1. Complete.
1. Confirmation
pollutants, likely pollutant sources,
description in
statement that
target audiences likely to have
Section 3.9 and
description is
significant storm water impacts, and
Table 7 of the
maintained in
why they were selected.
SWMP.
the SWMP.
5.
Describe Residential and Industrial/Commercial Issues
Describe issues, such as pollutants,
1. Maintain
1. Permit Year 5
1. Y/N/Status
likely sources of those pollutants,
description in
impacts, and the physical attributes
Section 3.9 and
FY21/22
of stormwater runoff, in the
Table 7 of the
education/outreach program.
SWMP.
6.
Distribute Public Education Materials to Target Audiences
Distribute stormwater educational
1. Provide public
1. Complete.
1. Y/N/Status
material to appropriate target
stormwater
groups identified in BMP 2. In lieu
education
of developing new materials, the
outreach materials
City may rely on Public Education
to the Leadership
Outreach materials supplied by the
Vance program
state, and/or other entities through a
for business
cooperative agreement.
leaders.
2. Provide outreach
2. Complete.
2. Y/N/Status
materials to the
Science,
Technology,
Engineering, and
Mathematics
(STEM) school
program.
3. Consider entering
3. Permit Year 5
3. Y/N/Status
into a partnership
with
FY21 /22
governmental
agencies such as
Triangle J
Council of
Governments
(TJCOG) to
leverage their
public education
and outreach
materials and
strategies.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 18
Stormwater Management Plan
Table 13: Public Education and Outreach BMPs
4. Consider entering
4. Permit Year 5
4. Y/N/Status
into an agreement
with the
FY21/22
Stormwater
Association of
North Carolina
(SWANC) to fund
public outreach on
television and
other media.
7.
Implement a Public Education and Outreach Program
Define and implement a public
1. Establish written
1. Permit Year 5
1. Y/N/Status
education and outreach program
public education
and
and outreach
FY21/22
document extent of audience
strategy.
reached via all outreach events.
2. Maintain
2. Permit Year 5
2. Y/N/Status
documentation of
audience reached
FY21/22
at each event or
strategy
implemented.
Permit
2.1.7, 3.2 3 and 3.6.5(c): Web Site
Ref. s
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.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual
Implementation
Reporting Metric
8.
Stormwater Web Site
Promote and maintain an internet
1. Maintain web
1. Complete.
1. Y/N/Status
web site designed to convey the
site.
stormwater program's message. The
2 post to the web
2. Permit Year 5
2. Y/N/Status
City's current stormwater program
site a list
website is located at
identifying the
FY21/22
https:Hci.henderson.nc.us/departme
ordinances or
nts/
other regulatory
engineering/stormwater_program.p
mechanisms
hp
providing the
legal authority
necessary to
implement and
enforce the
requirements of
the permit and
SWMP.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 19
Stormwater Management Plan
Table 13: Public Education and Outreach BMPs
3. Post to the
3. Permit Year 5
3. Y/N/Status
website relevant
post -construction
FY21/22
requirements,
design standards,
checklists and/or
other materials for
developers.
Permit
Ref.
3.2.5: Stormwater Hotline
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual
Implementation
Reporting Metric
9.
Publish Stormwater Helpline and Email Information
Advertise an existing City of
1. Identify
1. Permit Year 5
1. Y/N/Status
Henderson office number as the
appropriate City
stormwater helpline, create a
number to be the
FY21/22
stormwater program general email
stormwater
address, and ensure that inquiries
helpline.
are directed to Engineering staff for
2 Post the helpline
2. Permit Year 5
2. Y/N/Status
response/follow-up.
number and
stormwater
FY21/22
program email
address on the
Stormwater Web
Site with a note
that inquiries and
input on the
stormwater
program should
be directed to the
helpline.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 20
Stormwater Management Plan
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
This SWMP identifies the minimum elements and implementation of a Public Involvement and
t Participation Program that complies with applicable State, Tribal and local public notice requirements.
The City of Henderson will manage, implement and report the following public involvement and
participation BMPs.
Table 14: Public Involvement and Participation BMPs
Permit
3.3.1: Public Input
Ref.
Mechanisms for public involvement that provide for input on stormwater issues and the
stormwater program.
A
B
C
D
BMP
Annual
No
Description of BMP
Measurable Goal(s)
Schedule for
Reporting
Implementation
Metric
10.
Solicit Public Input on Stormwater Web Site
Solicit public input on stormwater
1. Post the helpline
1. Permit Year 5
1. YIN/Status
issues and the City stormwater
number on the
piogrun tluough a statement on Qie
Stounwatei Web
FY21/22
City stormwater web site, located at
Site with a note
https:Hci.henderson.ne.us/department
that inquiries and
s/engineering/stormwater_program.p
input on the
hp
stormwater
program should
be directed to the
helpline.
2. Post to the web
2. Permit Year 5
2. Y/N/Status
site a statement
that "Questions or
FY21 /22
comments on
stormwater issues
and the City of
Henderson
Stormwater
Program may be
directed to", and
include the
helpline number
and stormwater
program email
address.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 21
Stormwater Management Plan
Table 14: Public Involvement and Participation BMPs
3.3.2: Volunteer Opportunities
Permit
Measures to provide volunteer opportunities designed to promote ongoing citizen
ReI.
participation.
A
B
C
D
BMP
Annual
No.
Description of BMP
Measurable Goal(s)
Schedule for
Reporting
Implementation
Metric
11.
Stormwater Volunteer Community Involvement Program
Conduct and promote volunteer
1. Litter Pick-up
1. Permit Year 5
1. Y/N/Status;
opportunities designed to promote
Number of
ongoing citizen participation.
FY21/22
events.
2. Citizen Scientist
2. Permit Year 5
2. Y/N/Status;
Number of
FY21/22
events.
3. Adopt a Stream
3. Permit Year 5
3. Y/N/Status;
Number of
FY21/22
participants.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 22
Stormwater Management Plan
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
i - The City of Henderson 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 BMPs
Permit
3.4.1: MS4 Map
Ref.
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.
A
B
C
D
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
12.
Maintain Storm Sewer System Map of Major Outfalls
Maintain a current storm sewer
1. Map
1. Permit Year 5
1. Y/N/Status
system map showing major outfalls
Stormwater
and receiving streams.
Discharge
FY21/22
Outfalls
(SDOs) in
Cartegraph.
2. Finalize map.
2. Permit Year 5
2. Y/N/Status/Date
FY21 /22
3. Update map.
3. As Needed
3. Y/N/Status/Date
Permit
3.4.2: Regulatory Mechanism
Ref.
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.
A
B
C
D
BMP
No
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
13.
Illicit Discharge Detection and Elimination (IDDE) Ordinance
Maintain an Illegal Discharge
1. Maintain IDDE
1. Complete.
1. Y/N/Status; Date
Detection and Elimination (IDDE)
ordinance.
of Adoption;
ordinance or other regulatory
Ordinance
mechanism that provides the legal
Reference
authority to prohibit illicit
connections and discharges.
City of Henderson IDDE Ordinance
is available under Subtitle C,
Chapter 16, Division 3, Section 16-
37.8.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 23
Stormwater Management Plan
Table 15: Illicit Discharge Detection and Elimination BMPs
14.
Enforcement of IDDE Ordinance
Implement a mechanism to track the
1. Maintain NOV
1. Permit Year 5
1. Y/N/Status;
issuance of notices of violation
tracking in
Summary of type
(NOVs) and enforcement
Cartegraph.
FY21/22
and number of
actions as administered by the
enforcement
City of Henderson. This mechanism
actions issued.
aims to identify chronic violators for
2 Sort NOV
2. Annually
2. Y/N/Status
initiation of actions to reduce
tracking
noncompliance.
spreadsheet to
quickly identify
chronic
violators.
3. Implement
3. As Needed
3. Y/N/Status;
additional
Summary of type
enforcement
and number of
actions against
enforcement
chronic
actions issued to
violators.
chronic
violators.
Permit
3.4.3: IDDE Plan
Ref.
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..
A
B
C
D
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
15.
Written IDDE Plan
Maintain a written IDDE Plan as
1. Develop written
1. Permit Year 5
1. Y/N/Date
specified in Section 3.4.3 of the
IDDE Plan.
MS4 Permit.
FY21/22
16.
Dry Weather Outfall Screening and Source Tracing
Conduct outfall inspections and
1. Dry weather
1. TBD —
1. Y/N/Status;
field observations during dry
outfall
identified in
Number of
weather conditions to identify dry
screening.
IDDE Plan.
outfalls screened.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 24
Stormwater Management Plan
Table 15: Illicit Discharge Detection and Elimination BMPs
weather flow in accordance with
2. Investigate
2. Upon
2. Y/N/Status;
procedures in the IDDE plan.
sources of
Observation
Number of
flowing outfalls
of Dry
outfalls with dry
during dry
Weather Flow.
weather flow;
weather.
Source
investigation
findings.
Permit
3.4.4: IDDE Tracking
Ref.
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.
A
B
C
D
BMP
No
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
17.
IDDE Investigation Tracking and Documentation
For each case the City aims to track
1. Maintain IDDE
1. Permit Year 5
1. Y/N/Status;
and document 1) the date(s) the
investigation
Number of
illicit discharge was observed; 2) the
tracking
FY21/22
investigations,
results of the investigation; 3) any
spreadsheet.
potential illicit
follow-up of the investigation; and
discharges,
4) the date the investigation was
verified illicit
closed.
discharges,
remedied illicit
discharges;
enforcement
actions.
Permit
3.4.5: Staff IDDE Training
Ref.
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
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
18.
Employee and Contractor Training
Implement and document a training
1. Partner with
1. Permit Year 5
1. Y/N/Status
program for appropriate municipal
entity to acquire
staff, who as part of their normal job
illicit discharge
FY21/22
responsibilities, may come into
and connection
contact with or otherwise observe an
training
illicit discharge or illicit connection.
materials.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 25
Stormwater Management Plan
Table 15: Illicit Discharge Detection and Elimination BMPs
2. Conduct
2. Annually
2. Y/N/Status;
training.
Training date,
topics, and number
trained.
Permit
3.4.6: IDDE Reporting
Ref.
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.
A
B
C
D
BMP
No:
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
19.
Public Reporting Mechanism
Solicit public and staff reporting
1. Post to the web
1. Permit Year 5
1. Y/N/Status
illicit discharges, illegal dumping
site a statement
and spills through a statement on the
that "If you
FY21/22
City stormwater web site, located at
observe or
https://ci.henderson.nc.us/departmen
suspect an illicit
is/engineering/stormwater_program
discharge,
php
illegal dumping,
or spill, please
contact the City
of Henderson
Stormwater
Program at",
and include the
helpline number
and stormwater
program email
address.
20.
Public Education on IDDE
Inform public employees,
1. Update existing
1. Permit Year 5
1. Y/N/Status
businesses, and the general
public
public of hazards associated
education
FY21/22
with illegal discharges and
materials to
improper disposal of waste.
include illicit
discharges and
illegal dumping.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 26
Stormwater Management Plan
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the City of Henderson relies upon the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 and the NCGO10000 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
Meets Whole
Permit
Implementing
or Part of
Reference
State or Local Program Name
Legal Authority
Entity
Requirement
3.5.1 -
City of Henderson
15A NCAC
3.5.4
Delegated SEC Program*
Chapter 04
City of Henderson
Whole
3.5.1 -
State Implemented SEC Program
15A NCAC
NCDEQ
Whole
3.5.4
Chapter 04
* The local delegated Soil and Erosion Control (SEC) Program ordinance(s)/regulatory mechanism(s).
The City of Henderson also implements the following BMPs to meet NPDES MS4 Permit requirements.
Table 17: Construction Site Runoff Control BMPs
Permit
3.5.6: Public Input
Ref.
Measures to provide and promote a means for the public to notify the; appropriate authorities of
observed erosion and sedimentation problems.'
A
B
C
D
BMP
Annual
No
FDescription of BMP
Measurable
Schedule for
Reporting
Goal(s)
Implementation
Metric
21.
Municipal Staff Training
Train municipal staff who receive calls
1. Train
1. Annually
1. Document
from the public on the protocols for
municipal staff
beginning in
and report
referral and tracking of construction site
on proper
Permit Year 1
number of
runoff control complaints.
handling of
(FY19/20)
staff trained,
construction
training
site runoff
date(s) and
control
topics
complaints.
covered.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 27
Stormwater Management Plan
Table 17: Construction Site Runoff Control BMPs -
22.
Notification System for Public Reporting of SEC Problems
Solicit public reporting of SEC problems
1. Post to the
1. Permit Year 5
1. Y/N/Status
with construction sites to the City through
web site a
a statement on the City stormwater web
statement that
FY21/22
site, located at
"Please report
https://ci.henderson.nc.us/departments/en
concerns
gineering/stormwater_program.php
related to
sediment and
erosion control
at construction
sites to the
City of
Henderson
Stormwater
Program at",
and include the
helpline
number and
stormwater
program email
address.
Permit
3.5.5: Waste Management
Ref.
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,.
A
B
C
D
BMP
Annual
No.
Description of BMP
Measurable
Schedule for
Reporting
Goal(s)
Implementation
Metric
23.
Control Construction Site Waste
The City is implementing the delegated
1. Require
1. Continuous.
1. Y/N/Status
SEC program as published in Chapter
construction
23A of the City ordinance and complying
sites to meet
with NCGO 10000 permit requirements.
NCGO 10000
permit
requirements
for private
developments
as well as City
construction
projects.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 28
Stormwater Management Plan
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
_ This SWMP 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 Henderson and discharge into the MS4. These elements are
designed to minimize water quality impacts utilizing a combination of structural Stormwater Control
Measures (SCMs) and/or non-structural BMPs appropriate for the community, and ensure adequate long-
term operation and maintenance of SCMs.
In accordance with 15A NCAC 02H .0153 and .1017, the City of Henderson 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
State QAP Name `
State Requirements
Local Ordinance / Regulatory
Mechanism Reference
City Ordinance -Title IV- Public Utilities;
Tar -Pamlico River Basin Nutrient
Subtitle C- Public Works, Chapter 16-
Sensitive (NSW) Management
15A NCAC 2B .0258
Streets and Sidewalks, Article II -
Strategy
Excavations cuts and repairs, Division 3-
Stormwater Management
Table 19: Summary of Existing Post -Construction Program Elements
Permit Requirements for Plan Review and Approval
Municipal
Ordinance/Code
Reference(s) and/or
Document Title(s)
Date Adopted
3.6.2(a) Authority
Sec 16.-37.1
Rev 1-27-12
3.6.3(a) & 15A NCAC 02H.0153(c) Federal, State & Local Projects
3.6.3(b) Plan Review
Sec 16-37.6
Rev 1-27-12
3.6.3(c) O&M Agreement
Sec 16-37.4.d.2.b.iv
Rev 1-27-12
3.6.3(d) O&M Plan
Sec 16-37.4.d.2.b.v
Rev 1-27-12
3.6.3(e) Deed Restrictions/Covenants
Sec 16-37.4.d.2.b.v
Rev 1-27-12
3.6.3(f) Access Easements
Sec 16-37.4.d.2.b.v
Rev 1-27-12
3.6.2(b) Documentation
Sec 16-37.5
Rev 1-27-12
3.6.2(c) Right of Entry
Sec 16-37.7
Rev 1-27-12
3.6.4(a) Pre -CO Inspections
Sec 16-37.7
Rev 1-27-12
3.6.4(b) Compliance with Plans
Sec 16-37.6
Rev 1-27-12
3.6.4(c) Annual SCM Inspections
Sec 16-37.7.b
Rev 1-27-12
3.6.4(d) Low Density Inspections
N/A
N/A
3.6.4(e) Qualified Professional
Sec 16-37.7.b.1
Rev 1-27-12
3.6.6(a) Pet Waste
N/A
N/A
3.6.6(b) On -Site Domestic Wastewater Treatment
N/A
N/A
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 29
Stormwater Management Plan
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
3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post -Construction Reporting Requirements
Ref.
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.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
24.
Standard Reporting
Implement standardized
1. Track number of
1. Continuously
1. Number of plan
tracking, documentation,
low density and
reviews
inspections and reporting
high density plan
performed for low
mechanisms to compile
reviews performed.
density and high
appropriate data for the
density.
annual self -assessment
2. Track number of
2. Continuously
2. Number of plan
process. Data shall be
low density and
approvals issued
provided for each Post-
high density plans
for low density
Construction/ Qualifying
approved.
and high density.
Alternative Program being
3. Maintain a current
3. Continuously
3. Summary of
implemented as listed in
Tables 18 and 19.
inventory of low
number and type
density projects
of SCMs added to
and constructed
the inventory; and
SCMs including
number and
SCM type or low
acreage of low
density acreage,
density projects
location and last
constructed.
inspection date.
4. Track number of
4. Continuously
4. Number of SCM
SCM inspections
inspections.
performed.
5. Track number of
5. Continuously
5. Number of low
low density
density
inspections
inspections.
performed.
6. Track number and
6. Continuously
6. Number and type
type of
of enforcement
enforcement
actions taken.
actions taken.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 30
Stormwater Management Plan
Table 20: Post Construction Site Runoff Control BMPs
Permit
2.3 and 3.6: Qualifying Alternative Program(s)
Ref.
Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state
program requirements.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
I
Implementation
Metric
The QAP requirements are fully met by the existing QAP for post -construction, see references provided in
Table 18.
Permit
3.6.2: Legal Authority
Ref.
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 Storrnwater Management Program.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
This permit requirement is fully met by the existing post -construction program, see references provided in
Table 19.
Permit
3.6.3: Plan Review and Approval
Ref.,
4.6.1.1 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 MS4 permitted area, unless the
entity is subject to its own NPDES MS4 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).
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
This permit requirement is fully met by the existing post -construction program, see references provided in
1
Table 19.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 31
Stormwater Management Plan
Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.4: Inspections and Enforcement
Ref.
4.6.1.2 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
A
B
C
D
BMP
No.,
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
This permit requirement is fully met by the existing post -construction program, see references provided in
Table 19.
Permit
3.6.6: Fecal Coliform Reduction
Ref.
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.
A
B
C
D
BMP
No
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
25.
Pet Waste Management at Dog Parks
Conduct pet waste
1. Pet waste bag
1. Continuous
1. Y/N/Status
management practices at the
dispensing.
two City -owned dog parks:
2. Waste receptacles.
2. Continuous
2. Y/N/Status
"Pawsome Park" and
"Scentral Bark".
26.
Pet Waste Ordinance
Develop a pet waste
1. Ordinance
1. Permit Year 5
1. Y/N/Status; Date
ordinance or amend an
developed or
adopted; Ordinance
existing ordinance with a pet
amended with pet
FY21/22
reference.
waste management
waste management
component.
component.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 32
lStormwater Management Plan
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City
of Henderson 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. MS4 Operation and Maintenance Program
4. Municipal SCM Operation and Maintenance Program
5. Pesticide, Herbicide and Fertilizer Management Program
6. Vehicle and Equipment Maintenance Program
7. Pavement Management Program
The City of Henderson 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 BMPs
Permit
3.7.1: Municipal Facilities Operation and Maintenance Program
Ref.
Measures to manage facilities that are owned and operated by the permittee and have the potential
for generatingpolluted 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.
A
B
C
D
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
27.
Inventory of Municipally Owned or Operated facilities
Maintain a current inventory
1. Maintain
1. Complete.
1. Y/N/Date
of facilities and operations
inventory.
Updated
owned and operated by the
City with the potential for
generating polluted
stormwater runoff.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 33
Stormwater Management Plan
Table 21: Pollution Prevention and Good Housekeeping BMPs
28.
Operation and Maintenance (O&M) for Municipally Owned or Operated Facilities
Maintain and implement,
1.Develop
1. Permit Year 5
1. Y/N/Date
evaluate annually and update
Stormwater Plan
as necessary an O&M
with O&M
FY21/22
program for municipal
specifications for
owned and operated facilities
sand filters and
with the potential for
other SCMs at the
generating polluted
Operations Center.
stormwater runoff. The
O&M program shall specify
the frequency of inspections
and routine maintenance
requirements.
29.
Staff Training on Pollution Prevention and Good Housekeeping
Implement an employee
1.Partner with entity
1. Permit Year 5
1. Y/N/Status
training program for
to acquire
employees involved in
pollution
FY21/22
implementing pollution
prevention and
prevention and good
good
housekeeping practices.
housekeeping
training materials.
2.Conduct training.
2. Annually
2. Y/N/Status;
Training date,
topics, and
number trained.
Permit
3.7.2: Spill Response Program
Ref.
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
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
30.
Written Spill Response Procedures
Maintain written spill
1. Develop written
1. Permit Year 5
1. Y/N/Date
response procedures for
spill response
FY21/22
municipally owned or
procedures.
operated facilities.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 34
Stormwater Management Plan
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
3.7.3: MS4 Operation and Maintenance Program
Ref.
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.
A
B
C
I)
BMP
No
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
31.
O&M for Catch Basins and Storm Sewer Conveyance Systems
Maintain and implement an
1. Establish O&M
1. Permit Year 5
1. Y/N/Status
O&M program for the storm
program.
FY21/22
sewer system including catch
basins and conveyance
systems that the City owns
and maintains.
Permit
3.7.4: Municipal SCM Operation and Maintenance Program
Ref.
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.
A
B
C
D
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
32.
Identify Structural Stormwater Controls
Maintain a current inventory
1. Update
1. Continuous, as
1. Y/N/Date
of municipally -owned or
inventory.
controls are
Updated;
operated structural
installed.
Number/type
stormwater control measures
(summary).
(SCMs) installed for
compliance with the City's
post -construction ordinance.
33.
O&M for Structural SCMs
Maintain and implement an
1. Establish O&M
1. Continuous.
1. Y/N/Status
O&M program for
program.
municipally -owned or
maintained structural SCMs.
The O&M program will
specify the frequency of
inspections and routine
maintenance requirements
installed for compliance with
the City's post -construction
ordinance.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 35
Stormwater Management Plan
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
Ref.
Measures to minimize water quality impacts from the use of landscape chemicals. The permittee
shall provide routine pollution prevention and chemical use, storageand handling training, and shall
ensure compliance with permits and applicator certifications.
A
B
C
D
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation'
Metric
34.
Pesticide, Herbicide and Fertilizer Application Management
Ensure municipal employees
1. Ensure municipal
1. Continuous, prior
1. Y/N/Status
and contractors are properly
employees are
to start of work.
trained and all permits,
licensed.
certifications, and other
2. Ensure
2. Continuous, prior
2. Y/N/Status
measures for applicators are
contractors are
to start of work.
followed.
licensed.
Permit
3.7.6: Vehicle and Equipment Maintenance Program
Ref.
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
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation-
Metric
35.
Minimize Contamination of Stormwater Runoff from Vehicle and Equipment Cleaning Areas
Describe and implement
1. Repair wash pad
1 Permit Year 5
1. Y/N/Status
measures to prevent or
that discharges to
FY21/22
minimize contamination of
sanitary.
the stormwater runoff from
2. Wash vehicles
2. Permit Year 5
2. Y/N/Status
all areas used for vehicle and
and equipment at
FY21/22
equipment cleaning.
wash pad or other
location
discharging to
sanitary sewer.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 36
Stormwater Management Plan
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
3.7.7: Pavement Management Program
Ref.
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.
A
B
C
D
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
36.
Maintenance of Streets, Roads, and Public Parking Lots
Evaluate existing and new
1. Do not conduct
1. Continuous
1. Y/N/Status
BMPs annually that reduce
street washing.
(current City
polluted stormwater runoff
practice).
from municipally -owned
2. Conduct street
2 Continuous
2. Y/N/Status
streets, roads and public
parking lots within their
sweeping.
corporate limits. The City
will evaluate the
3. Evaluate existing
3. Annually
3. Y/N/Status
effectiveness of these BMPs
and new best
based on cost and the
practices.
estimated quantity of
pollutants removed.
DRAFT NCS000542 SWMP
City of Henderson
February 5, 2021
Page 37