HomeMy WebLinkAboutNCS000605_Hudson 2021 APPROVED SWMP_20210511Final Stormwater Management Plan
Town of Hudson
NCS000605
April 19, 2021
� ��D;..� E Q
I&rrkv�n.ntsi 0us;�ly
APPROVED
fIj. ' 1" May 11, 2021
Jeanette Poive11
MS4 Progi u Coordinator
Table of Contents
PART1: INTRODUCTION............................................................................................
PART 2: CERTIFICATION ..............................................
PART 3: MS4INFORMATION..................................................................................................................3
3.1 Permitted MS4 Area .......................... ..............................
3.2 Existing 5 MS4 Mapping ......................
3.3 Receiving Waters..........................................................................................................................
3.4 .......................................................................................I........
MS4lnterconnection.....................5
.).5 Total Maximum Daily Loads (TMDLs) ..............
..................6
........
3.6 Endangered and Threatened Species and Critical Habitat .................................... .... . 7
3.7 Industrial Facility Discharges............................................................................ 8
3.8 Non-StormwaterDischarges .........................................................................................................9
3.9 Target Pollutants and Sources...................................................................................................
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION...................................13
4.1 Organizational Structure .................................................... ..................................................... ....I
4.2 Program Funding and Budget.....................................................................................................15
4.3 Shared Responsibility.............................................................................................................4...15
4A Co-Pernuttees.........................................................................................................................0....17
4.5 Measurable Goals for Program Administration......................................................
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ...................
INVOLVEMENT AND PARTICIPATION PROGRAM..•��• �•� � �•-•� ................ 28
PART 6: PUBLIC
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM ........................
. ..... 33
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM......... """"' ...43
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ... •-• •..••57
List of Tables
Table 1: Summary of MS4 Mapping
Table 2: Summary of MS4 Receiving Waters
Table 3: Summary of Approved TMDLs
es/Babitat Impacted by Surface Water Quality
Table 4: Summary of Federally Listed Speci
Table 5: NPDES 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 BMPs
Table 12: Summary of Target Pollutants & Audiences
Table 13: Public Education and Outreach BMPs
Table 14: Public Involvement and Participation BMPs
Table 15: Illicit Discharge Detection and Elimination BfPConstruction Site Runoff Control Program
Table 16: Qualifying Alternative Program Components
Table 17: Construction Site Runoff Control BMPs
Table 18: Qualifying Alternative Progr
am(s) for Post -Construction Site Runoff Control Program
f Existing Post -Construction Program
PART lc INTRODUCTION
The purpose of this Strut Management Plan (SWMP) is to establish and define the means by which
the Town of Hudson will comply with its National Pollutant Discbarg applicable provisions of the Cstem rlean Water
Municipal Separate Storm Sewer System (MS4) Permit and the P
Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent
practicable.
on will
ntal
This SWMP identifies
enforce, evaluate and reporto the North Caroli ecific elements and minimum measures a D MLR)ent of order
tthe Town of o com comply
develop, imp Minerals and Land Resources (DEMLR) n order to comply with
Quality (NCDEQ) Division of Energy, This ermit covers activities associated with
the MS4 Perm t number NCS000605, as issued by NCDEQ. P
the discharge of stormwater from the MS4 as owned and operated by the Town of Hudson and located
irements within the corporate limits of the Town of Hudson.
In preparing this SWMP, the Town of Hudson has evaluated its MS4 andne o
dseaddresglocal water
develop a comprehensive 5-year SWMP that will meet the c mm m 'with the perm t. The SWMP will
quality issues and provide the min mum measures necessary P y
be evaluated and updated annually to ensure that the elements and minimum measures it contains
continue to adequately provide for pemrit compliance and the community's needs.
Once the SWMP is approved by NCDEQ, all provisions contained and referenced n th s SWMP, along
with any approved modifications of thJ W hD s o th approved SWMP wrll requ re Teout and come
bm ttal,
enforceable parts of the perm t. Any ng on the nature
review and approval by NCDEQ, and may require a new public comment period dependi
of the changes.
pINALNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 1
PART 2: CERTIFICATION
By my signature below I hereby certify, under penalty of law, that this document and all attachments were
ystern de sied to
prepared under my direction andsupervision in accordance with a s or
the information submitted, Ba se,
on my inquiry assure
the person or
personnel properly gather
reformat h submitted thesystem,
to the best those
perandand belief, trusons directly e,
accurate,
cur te, andgcohmpletermation, the
nformation, including the possibility of
I am aware that there are significant penalties for submitting false i
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 principal executive officer or ranking elected official.
❑ 1 am a duly authorized representative and have attached the authorization made in writing by a principal
executive officer or ranking elected official which specifies me as:
erall responsibility for stormwater matters.
❑ A specific individual having ov
❑ A specific position having overall responsibility for stormwater matters.
FINALNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 2
PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This Stmmwater Management Plan (SWMP) applies throughout the corporate limits of the Town of
Hudson, including g all regulated activities associated with the discharge of stormwater from the MS4. The
ma "in `udin the corporate limits
of Town of Hudson as of the date of this document.
FINAL NCTo n of H dson
April 19, 2021
Page 3
3.2 Existing MS4 Mapping
The current MS4 mapping includes outfalls located within the To flow wn c directiorn, coverts ditchesginlet n
will be adding the following elements to the map: s p
catch basins, manholes outfallL sizes and Condit ons (Reference BMP 20).
The Town oer the detnution provided below. The Town will be ver fy ng all
f Hudson has a historic count of 82 outfalls per the GIS layer crea e ;
certain that all of these are majorp let on of BMP 20.
elements as mentioned above in the comp
FInAI-NCTo nofAudso�n
April 19, 2021
page 4
Table 1: Summary of MS4 Mapping
percent of MS4 Area Mapped
10
Outfalls* Mapped
82 total
No. of Major
oint where the MS4 discharges from a pipe or other conveyance uire a ditch) directly
*An out is a p ou alls are required to be mapped to meet permit req wind for tindu major
al Zoned
into surface waters. Major
outfall is a 36-inch diameter pipe or dischaarea m 2 acaes�ge area > 50-acres;
areas a 12-inch diametw pipe or a drainage
3.3 Receiving wags
licable water quality standards listed below are compiled
The Town of Hudson MS4 is located within the Catawba River Basin and d scharges d rectly rnto
receiving waters as listed in Table 2 below. App
from the following NCDBQ sources:
e Wsterbody Classification Ma
o Im>aired Waters and TM
nL6 a� List
o Most recent NCDEQ
Table 2: Summary of MS4 Receiving W je
Number tyiasaiu4�=�� 1.5 .,0�(d)
Creek (I1-55- Impairment-Benthos
(0.5)) and
(11-55-
(1.5))
nwder Creek
(11-55-2 C
3.4 MS4lnterconnection
The Town of Hudson MS4 is intercoected with another regulated er ed. The Town of Hudsonowill be
from the Town of Lenoir MS4. The number of interconnections entering the Town of Hudson n will b (reference
the Town of Lenoir is unknown due to the storm sewer not being mapp
in the future mapping the storm sewer lines and water flow to help determine interconnectivity
BMP 20)
stormwater from
The Town of Hudson MS4 is interconnected with another regulated MS4 and directlyThe Town will be
therTown of Hudson MS4 is unknowns MS4, toduet the to The 'lumber sewer not being mappreceiv ng
sewer lines and flow direction in the future (reference BMP 20)
mapping the storm
FINAL NCSo000605 n of Hudson
April 19,2021
Page 5
Currently,
a limited amount of data is available. Field staff will collect further data using a GIS mapping
Mappinga
existing plans or blue p lication off of field techn
conditions. Staff will develop
data recording, and pre -
application li locate flow direction, inverts, ditches, inlets, catch basins, manholes outfall, sizes an
velo from the Town of Hudson.
The MS4 does nterconnect with the statewide NCDOT MS4 and includes:
ction is receiving stoimwater from the NCDOT MS4. The number of
a. The interconne
interconnections is uilrno
b The interconnection is not discharging st"awater nto the NCDOT MS4. The number of
interconnections is unknown
c. ing does not identify interconnections with the NCDOT
The Town of Hudson MS4 mapp
MS4.
of Hudson MS4 mapping does include NCDOT MS4 outfalls.
d. The Town
3.5 Total Maximum Daily Loads (TMDLs) the map
s listed n Table 3 below have been approved within the MS4 area, as determ ned by
The TMDLO to
any watershed
and list provided on the NODE Model'uis & A sessment Unit web a e. The Allocation (WLtable also indicates am
ormm
whether the approved TMDL has a spe MS4, and ter whetheaa Water Quality program
directly receiving discharges from the permitted
has been implemented to address the WLA. Outreach education and stream cleanup helps with the
reduction of waste load allocation within approved TIvIDL rmmiciPalit es.
FINALNCTo wofHudsorr
April N, 2021
Page 6
3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or cria itical habd andThretare identified within the
cul
regulated MS4 urbanized area. Based upon a review Map
1 fe eCl- e, the species listed in Table 4 have
S ecies of Concern b Count for North Carol Ma and Listed sLAC ecies believe io or known to in
North Carolina man as provided by the U.S. Fish_ li —
by the quality of surface waters with n their habitat.
the potential o occur cur within the regulated MS4 Of those species listed, Table 4 summarizes s the species
that may be significantly impacted
Water Quality
Table 4: Potential Federally Listed Species/Habitat Impacted by Surface
s Pcies Group Federal L
�taucv„,yam �_-. - Ilyin squirrel T
coloratus - - eared Vertebrate
Myotisseptentrionalis barthernlong E
bat Vertebrate
Corynorhinais Virg�iabig-eared
townsendii a
�hus
Edmons's Jnaxc�aia -
Invertebrate
ARS
margarita Margarita R ver
skimmer E
a Spruce -fir moss
Invertebrate
spider Vascular Plant T
naniflora Ded
warfDwarf� —
Partleaf ed
purpurea
var
3.7 Industrial Facility Discharges
The Town of Hudson MS4 jurisdictional area includes the following industrial facilities which hold
ed from the NCDE
NPDES Industrial Stormwater Permits, as determ nMa s & Perm' Data web a Te•
F INAL NCTo on of Hudson
April 19, 2u2
Page 7
Table 5: NPDES Stormwater Permitted Industrial Facilities
g68 Non-Stormwater Discharges es have been evaluated by the Town of Hudson as
The water quality mipacts ofnon-Stormwater discharg
summarized in Table 6 below. The unperomted non-Stormwater flows listed n incidental do not
significantly impact water quality. The Town of Hudson has evaluate
residential and charity car
washing and street washill for possible significant water qualityimpacts.
Street washing discharges are addressed under the Pavement Management Program in Part controlled by the
10 of this
SWMP. The Division has not required that other non-stormwater flows be specifically
Town of Hudson. e directly
that does not contain detergents or does not discharge directly
do
Wash water associated with car washing es ofnon-Stormwater discharges
the Town of Hudson to determine of the below
into the MS4 is considered incidental. However, these p
contain detergents have been evaluated
by Town of Hudson will address the possibility as outlined in Part 5,
Sig f cantly impact water quality. of good
mentioned water quality impacts through public education and good housekeeping, the g,
BMP 3.7, and Part 10 BMP 46-49, 50, 54, 55, 57, 58 and 62 with a focus on the tra rung
housekeeping practices,
FINALNCTo 06ofHuds n
April 19, 2021
Page 8
3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the Town of Hudson is not aware of other
significant water quality issues within the permitted MS4 area.
ollutants identified rani gand ideout ntifies firs the assooc 3 of this a edhe
Table 7 below summarizes eted audienhe water ces attributed to each p
likely activities/sources/tang acts.
SWMP program(s) that address. In addition, the Town of Hudson has evaluated schools, homeowners an
businesses as target audiences that are likely to have significant stormwater found to be concerns within
Within the table below the following target pollutants have been commonly
the community,
Litter: Illegal dumping has occurred and been noted by code enforcement officers within the Town.
Cases of both illegal construction waste dumping and general residential or school dumping have been
s that damage the pipelines leading back to the
noted by code enforcement officers. This litter poses a threat to both our water bodies and the MS components
uses a threat to groundwater if chemical leaching or breakdown of
infrastructure, as the fitter can create clogs and backups road side
stream. Some litter even. p
of the litter. The dumping has been found typically
into heavy metals occurs due to weathering
but also in secluded urban areas.
Sediment: Previous installed erosion control measure have been removed or fallen
. Correctly
ith
len or in
sediment buildup is largely attributed to mismanaged construction sites code enforcement officers
sediment fences. It has been noticed n both reports from citizens and y
work. This
onto down slope private properties, and insome emoove
there are several cases of construction sites not maintaining the r erosion control fences mg
as the sediment is limiting the drains ability down for a
has led to sediment buildup near storm drains,
causing water to build up in nearby properties and had the issue solved but even being
runoff. In all cases code enforcement has respondedquires.
short time can prove to have significant effects. Erosion control fences are required for sediment control
permits during construction by the DEQ throughout the entire construction p
Gray Water: Straight piping washing machines out of the house
Residents have noted a few homes have had their washing machines straight -piped out of their homes by
creating makeshift piping using water hoses exit at windows. Homes are to be connected to the
appropriate sewer system. This proves to be a source of deteergdentsunoap� entering hes allow for soaps or
cleaned in the correct areas (such as vegetated
residential neighborhoods. In addition: residential, charity,
This allows for toxic contaminants to enter our
waxes to enter the storm drain when vehicles are not being
patches or rvia thareas
e
stormdraindra n system t do not have rm drains).
waterway
FINAL NCS0o0605
of Hudson
April 19, 2021
Page 9
Fats Oils and Geese traps ase: He for 3alth DP Department has
priate removal* noted several cases where restaurants do not empty
or own/rent grease or even owning,
The Health Dep in the grease or all
the
artment has reported several restaurants in Hudson not maintainmg, issues.
grease traps. This has led to cases of the restaurants either illegally dmnen g� waste contributes to this
grease to drip onto nearby mpermeable surface — which would ease w th filly lead to water quality
out the grease but it also can impair water
Overflow from a lack of maintenance or throwmge poses a physical risk
problem. This is a health violet on since the grease
down the storm drain.
bodies with an influx of water insoluble grease going labeled or stored
Chemicals: Totes have been noted in industrial areas not properly own/unmarked chemicals are
Town staff, along with some citizens have reported that containers of unkn
to otern al soil and water cone T wn has o�dxthat the incorrect spill
unlabeled in select industrial sites, leading phe containers correctly,
cleanup procedure. In addition to not labeling to minimize risk to the water bodies from seepage,
containers are not being correctly stored n a way
damage to the containers, or spills.
Animal Operations: A challenge to ensuring water quality for several factors.
operations are agriculture operations that raise cows, pigs, chickens; or other livestock as a
byproducts of the animal, the latter being more problematic as the excess
Animal op h oxia in the water body. In a similar
product, be it from meat or hic
s with
nutrients will lead to eutrophicat on which can eventually causing YP
vein, ag 46 streams are/were imp acted by fecal
ricultural innoff often caries excess fertilizer which also will cause eutr pollutant it is hardhication in to locate
effects. Within the Catawba R ver Basin roughly Dint source p that makes
its cascading fisted on the 303(d) list. As this is a non-p
coliform, with 10 being � agricultural
hohowever
to occur. Roughly 20°/ of land use within the basin is ag
the exact source of this runoff, however n much of the watershed there is agriculture zonmg
it likely for these types of impairments
Underground storage tanks: Storage devices installed below ground that contain hazardous
materials/waste,
gasoline, fuels such as pr°Pa°a= industrial them cals/oils, and most °u t be welln
connected to the sanitary sewer. Any underground storagecan cause
These tanks can contain g g. The leaks
waste in areas not directly d due to ground, harming the soil, groundwater/water table,
maintainedlmorrhored, and correctly i s leak into the gr risk of them the so tank
whatever chemical the tank is stor ng fed from groundwater. If a fuel or industrial chemical
and is
to toxic soil, contam nated gr processes
and even surface waters will
that are being
leaking, If a septic tank is leaking, it can overwhelm the natural pathogens
the chemical will leach into the soil —leading n oundwatex, or allowing P
possibly impairing a stream water body. streams
Of the soil (infiltration) leading
to notr ent overload fecal coliform impaired streams listed can have
to enter, increasing the risk of disease. The 10 303(d)
some attribution to septic tank leakage. uall varied number of effects
Illicit discharges: Originate from a variety of sources, with an eq Y
dependent on the chemical that is released.
FtNALNCTo 0605 of Hudson
April 19, 2021
page 10
Typically, illicit discharges come from businesses, residents or municipal facilities who dump
chem cals
solut ons, pa nts, metals, etc.
into storm drams either incidentally due to a lack of IDDE education or general carelessness. These
chemicals can vary g streams impaired from causes related to
generated
greatly and call include grease, oils, chemicals, cleaning
This is a recognized problem as we have several 303(d)
substances or attributions given to unclean discharges into the streams - e addition to reports g
by the municipality. Many of the 303(d) benthI impaired streams call it iscattrareas to IDDE issues, but
they are often from inexact non -point sources that are attributed to illicit discharges
es, or municipal employees dump waste randomly in
Illegal dumping: When residents, business
non-permitted dumping areas.
This waste can widely vary, causing a variety of problems. For examPle, citizens dumping televisions on
the side of the road to avals or chemicals inside th
oid dumping fees, which allows for the an be a case of businesses damping
each
lead and other metals). n it, or residuals of the
out as stormwater passes it (mercury, h the waste, either carry g
aders dumping sediment into areas without the correct
waste in watershed areas where runoff passes throug
waste into water bodies. It can also be a case of gr g4 system.
che
ents, or debris entering the stream/M
alaote into preca odies. The debris and chemicals accumulate over time and lead to system.
mca
tion
impairments, PH issues, turbidity mpa rm
Improper disposal of waste: e waste, to
problematic because it allows chemie les not giving atcarlbattery to the
Improper disposal of waste is p be hard to track. For examp
enter the environment m ways that may acid and lead to enter the soil which managers and is
correct waste management facility can allow for battery municipal waste . Other
drains/collects in the groundwater. This problem has been noticed by
chemicals from batteries leaching into
difficult to track as often the improper disposal waste is mixed in with the standard refuse. O er
examples include grease going down sinks clogging MS4 systems,
the groundwater, oil from oil changes not going to the correct facility, etc.
Table 7: Summary of Target Pollutants and Sources
Public Education & Ur
Residents, Businesses, Schools public Partici ation
Public Education & 01
Construction Activity Construction Program
Sediment
Gray water
Oils and Grease
Businesses (Restaurants) public Education & Uutreacn
Industrial, Business and Resident al publicEducation& Outreach
Operations
a
FINAL NCTo On of Hudson
April 19, 2021
Page 11
Storage Tanks Business and
Illegal Dumping ana
mproper Disposal of Waste
Gene c, Businesses,
MunicipalEmployees
General Public, Businesses,
Municipal Employees
Illicit Discharge
Public Education & Outreach
Illicit Discharge
Public Education & Outreach
FHeALNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 12
pART 4: STORMS ATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure WpCOG) to coordinate
Best Management Practices to
The Town of Hudson has contracted W estern Piedmont Council of Goven monram the Town of Hudson
Stor nwater Management Plan efforts, to ensure theTownisfacilitating
the program
protect water quality- While WpCOG will be the primary ort actions to WPCOG. The fol' ement. Each
staff will be training to handle internal procedures and rep
th
rmwater
Organizational chart is In down by the six elements associate mlanageo and then on to the Stormwater
of the positions under the elements will report back to the primary
Program Administrator.
of Responsible Parties
Table 8: Summary Responsible
SR MP Component
Town Manage
Stormwater Program
Administration
SWMP Management planner/Natural
Resources
Rebecca
own
FINALNCS000605 SWh'lp
Town of Hudson
April 19, 2021
Page li
WpCOG Senior
Johnny Wear -
Public Education & planner/Natural
Outreach Resources WPCOG
Administrator Johnny Wear
WPCOG Senior
Public Involvement & Planner/Natural
Participation Resources WPCOG
Administrator Todd Justice
WPCOG Code
Illicit Discharge Enforcement Officer
Detection & NCDEQ — Asheville
Elimination N/A
N/A Regional Office
Construction Site WpCOG
Runoff Control Jack Cline
WPCOG Stormwater
Post -Construction Administrator
Stormwater WPCOG
Management Johnny Wear
WPCOG Senior
Pollution planner/Natural
Prevention/Good Resources
Housekeeping for Administrator
Operations WPCOG
Municipal Op WPCOG Stormwater Jack Cline
Municipal Facilities Administrator
Operation & WPCOG,
Maintenance Program Jack Cline; TBD Volunteer/Town Fire
Stormwater Department, if
Spill Response Program Administrator and a licable
Volunteer Emergency
Services To of Hudson Public
Town of Hudson Public TBD Works Department
MS4 Operation & Works Operator
Maintenance Program Jack Cline Town of Hudson Public
Town of Hudson Public TBD;
Works Department and
Municipal SCM Works Operator and WPCOG
Operation & Stormwater
Maintenance Program Administrator Jack Cline Town of Huardstment and
Town OfHudsonPublic TBD> WoxksDep
Pesticide, Herbicide & Works Operator and WPCOG
Fertilizer Management WPC OGStormwatex
Town of Hudson Publi
Program Adm n strator Department
Town ofHudson public TBD Woks
Vehicle & Equipment Works Operator
Cleaning Program
FINALNcsoOO605
of Hudso
April 19,2021
Page 14
Woo Huosor
Pavement; nagement Woik, operator
Program
in of Ijudson Public
Works Department
4.2 Program Funding and Budget and staffing to
adequate funding
1 with the requirements of the NPDES
In accordance with the issued perm t, the Town of Hudson shall With l
mplement and manage the provisions of the S3 and comp y
and compliance fee, which is billed by DE
et includes the permit administering eaz of the permit cycle will will
used to
MS4 Permit. The budg emit mandates, the first y din mechanism will be
Due to the increase NPDES p needs. The fun g program will
annnallysis to determine how the stormwater
determine a base line for �letion oof atfisoal gap anal}dmg
analyzed through the comp obtained.
be implemented and funding
adopted, and
ents for the following services:
Currently, the Town of Hudson, has a two year °Ontract (which will need to be modified,
Public Involvement and Part cipat on Progra ,Illicit Discharge
signed every two years) with R estern Piedmont Council of Governor d pollution
Public Education and O Pr gPr a ' ear Period (years 1
Post-ConstThe1oll Site ccurrent cRontrac�amounol P oxgthe 2-y
Detection and Eliminationprograms• responsible for the cost of the
prevention and Good Housekycle) i $33 772.00. The Town will be
ermit Cycle) aid to the state. Any fees charged to the development community
and 2 of the NPDES p wh ah is to be p the Town
May
NPDES permit renewal, and other associated fees will help offset cost. The Town y t
ections, Plan Review, implemented; these fees would be collected by
for BMP Insp fees should be imp ort the stormwater program
determine that storm bills. The goal would be for the fiords collecte to sup
funding will be
tax
through or utility and other water quality efforts. Revenue versus
through mapping outfalls, stream repanrs,
reviewed each year to determine needed changes• eaz contract, pr or to the last month, a
Should the Town two y
erniit and stormwater Management Plan would need to occur, The
of Hudson choose notto renew the existing eft cycle.
NPDES p out the 5 year NPDES p
revision to the existing uired to fully carry
Town of Hudson would be req
4.3 Shared Responsibility witli �,TpCOG (referred to as
um control measures, which areas str regent as the
Beginning July 20195 the Town of Hudson will share the responsibility,
entity), to implement the following minim' be subj ect to enforcement
NPDES MS4 Permit requirement. The Town °at on and may ors responsible or
correspondingfails to perform the permit obligation permit
obligation. Table 9
nor the other entity fully performs the P
compliance if the other entity
action, if neither the Town al Hudsonponsibilities for each program.
below summarizes individual responsibilities
Table 9: Shared ResponsibilrtieT
F7NALNCS000605 SWMP
Town of Hudson
April 19,2021
page 15
3ener—al eqR u rements
Public Education and
Outreach
Public Involvement and
Participation Program
IIlicitD� h gr eac Detect
and Elimination Progra
�,..,�r.,ction Site Runc
Pollutio on and
Good Housekeeping
Pro ams
Total Maximum DailY L
Stormwater t azui�,o.Lr
Stormwater Partnership
Stormwater Partnership
i Stormwater Partners"IF
Stormwater raz�u�i ��ur
Stormwater Partnership
Y
Y
GI
FihALNCS000605 SWMP
Town of Hudson
April 19, 2021
page 16
4A CO- Permittees eruuL number
There are no other entities applying for co-permittee status under the NPDES MS4 p
NCS000605 for the Town of Hudson.
4.5 Measurable Goals for Program Administration
Referencing, MS4 Inspection Report for the Town ofHudson - Program Implementation, on, Documentation
& Assessment, Permit Citation - II.A.2. Stormwater Plan Implementation &Evaluation, mwat Keeping
the Stormwater Plan UP to Date, ILA.4. Availability of the Stormwater Plan RA.S. Stormwand
ater Plan
procedures for doing so. In order to meet the State
Modifications and ILA.7 Written Procedures; the Town has not evaluated the performance conents will be
effectiveness of the program and had not develop any p Management Plan: SWMP,
requirements for this section, a self -assessment and the effectiveness of the Man Permit Year One of the
will be adopted during ear O
completed annually. Written procedures, otherwise known as, Stormwater snag
has been drafted, but not adopted at this time. The he Mp SW
it-
NPDES permit cycle following the acceptance of the SWMP and issuance of the NPDES p
MS4 Insp for the Town of Hudson - Program Implementation, Documentation &
of Lenoir on the Town'
City s behalf
ection Report
llicit d scharge compla nts and enforcement actions; however,
Assessment, Permit Citation - IILA. Pr°gram Documentation; The
maintained some documentation regarding to the Town's Stormwater program (e.g., no
there was an overall lack of documentation relating
documentation for inspectrons, maintenance activities, or educational programs).
MS4 Inspection Report for the Town of Hudson -Program Implementation, Documentation &
trol
Assessment, Permit Citation - III.B. Annual Report Subm ttal: The latest MS4 annuai report submittedurn con
year, The report ncluded a brief description °f ti ecif e miles ones for
was for the 2014-2015 reporting y report lacked deta l regazding sp period. Instead,
or what was accomplished during the reporting
measures and initiative at the time. However, e rep lementation, which largely had not yet been
the measures, overall plan accountability, ro am imp
the report described plans for future MS4 p gr
implemented. Further, the 2014-2015 report did not include a fiscal analysis (Permit Citation - � o the
Management Program using Public Education &Outreach, Public
The Town of Hudson will manage and report the following Best Management Practices (BMP )
administration of the Stor nwatex Detection &Elimination, Post -Construction Site Runoff
Involvement & Participation, Illicit Discharge
Control, and Pollution Prevention & Good Housekeeping.
I Annual Self -Assessment
fi'INALNC�0wOnofH don
April 19, 2021
Page 17
Perform an annua, ��u�-•--
gprAP implementation,
suitability of SWAP proposed
commitments and any utilizing
changes to the SWMP utixo
the NCDEQ Annual Self-
1. out
the Annual
al Self-
APermit Years l-4
submit t
Assessment to NCDEQ
prior to August 31 each
year.
Lcation T ically 1. Yesmo
2 permit Renewal App 1. TBD — TP
1, participate in an Permit Year 4
Audit stormwater program compliance NPDES MS4 Permit
implementation for comp Compliance Audit, as
with the permit and approved scheduled and performed
SKIMP, and utilize the results to b EPA or NCDE 2 Permit Year 5 2. Yes/No/Part�al
prepare and submit a permit 2. Self -audit and
renewal application package. document any
stormwater program
components not audited
by EPA or NCDEQ Audit
Utilizing the DEQ
Template. Submit Self -
Audit to DEMLR
(required component of
permit renewal
a lication acka e 3. Date of permit renewal
3. Certify the stormwater 3. Permit Year 5 application submittal
Permit renewal
application (permit
renewal application
form, Self -Audit, and
Draft SWMp for the next
5-year permit cycle) and
submit to NCDEQ at
least 180 days prior to
permit ex nation.
FIN AL NCTo n of Hudson
April 19, L"
Page 18
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM am to distribute educational
The Town of Hudson will implement a Public Educat on and Outreach program acts of storm water
materials to the common or conduct equivalent outreach actreduct es bouth�n'orm water runoff.
discharges on water bodies and steps the public can take to reduce Pollutants
Target Audiences, and 11.B.2.h. Public Education and outreach
issues-
program- In reference to MS4 Permit Self Audit Report -Public Education and Outreach, Permit Citation II.B•_.a
uiremems,11 B.2.c. oals &objectives for community public education
Program Req
Program: The Town of Hudson had not defined g
Stormwatex impact target audiences and extend of exposure had not
been recorded at
and outreach events. Part 3.9 of this S which will be addressed by
n Tab12 below. in addition, the Town of
The target audiences and identified pollutants listed in le
the Public Education and Outreach Program, are Summarizedin
associated with illicit
Hudson is required to inform businesses and er disposal of waste the general public of the
schar'cs, illegal dumping and improper
r.,._a, ,.,, w;t1 manage, implement and report the following public education and ouuea�.�
Town of tiuusui,
April 19, 2021
Page 19
�tormwa«• - --- 1. Yertmr c °°"
1. Develop and
Stormwater fliers will be distribute fliers at
distributed to Town residences, Town events to create
municipal employees, businesses,
Stormwater awareness. 2 Pexnut Year 2
and industrial facilities through 2 Develop and
Stormwater events. Five topics
wi ill be addressed over the term of lb citdischarges. 3. Permit Year 3
the permit; general stormwater 3 Develop and
awareness, illicit discharges, distribute fliers for
illegal dumping, chemicals and illegal dumpin . 4. Permit Year 4
proper disposal of waste. 4. Develop and
distribute fliers for
chemical awareness. 5 permit Year 5
5. Develop and
distribute fliers fox
4 Public Event Outreach 1. Annually
Provide stormwater educational I. Staff will have a
eneralpublic boo thattbeannual permit years 1-5
information to the g Hudson Butterfly
at community events.
Festival to disperse
Stormwater outreach
COVID-19 has l m ted outreach materialslawareness
opportunities at public events due h the use of
to their cancelation in 2020I2021. interactive educational
As such, alternative ways for this
games and activities.
type of outreach will be
necessary. Alternatives, including
but not limited to, booths at
farmers markets or a an th inside
the library (if open)
vide
these opportunities while still
being safe for participants.
distr buted at events..
1. Number of attenae
at the outreach booth
during the butterfly
festival.
FINAL NCS000605 SWMP
Town of Hudson
April 19, 2021
page 20
Youth Community Outreach
alternative outreach permit Years 1-5
opportunities if the
Butterfly Festival is
canceled, or as an
additional outreach
supplement. Such
opportunities include
but are not limited to:
an outreach booth at
local Libraries, and/or
an outreach booth at
farmers markets, or
other events if they are
still available at
different times
1. W YC:UU wiu
act vities, and educational provide nstruct on and
stormwater
materials to students and youth
through educational activities
community groups to youth community
classrooms, workshops, classrooms,
community Presentations, and/or groups,
workshops,
hands-on activities related to community
stormwater best practices s can
targeted community groups
include: boy scouts, gh1 scouts, 4-
g clubs, school environmental
programs, church/religious
groups, community environmental
groups. Many of the individuals in
these groups will hit the same
target audiences as student
outreach but can be more easily
2. Utlllze uic .. _ �-�-
storm stencils during
outreach events to
educate community
members on the
mpact of dumping
Iinto storm drains as
well as add caution
vns to them
1.
Permit Years 1-5
Z. Annually
Permit Years 1-5
at altemative outreach
booth
Event/location of
alternative outreach
booth
1. Number of
activities/events
provided;
Number of participants
present at these
events/activities.
2. Number of storm
drains stenc led
FINAL NCTOoOdo of H d on
April 19, 2
Page 21
met—dne to the nature of Imethoc
f wtation coveringpermit Yearsorgan nationswater topics to
sented in digital
ooms and/or
ded to teachersowerPomtwill
esented by
ers and/or staff
udenthod such as an
Staff lrlw design and distrmuic
new printed materials for target
audiences to aid stormwater
education
] .Staff wIll create
1.
printed material for
local government
distribution address ng
stormwater best
pracuw�.
2. Staff will distribute 2. See B1vIP 3
pr nted materials at
events,school
presentations, and
have them on display
for public acquisition
n Government
buildings. The flyers
will also be hosted on
he, WPCOG website
to enable digital access
to this resource.
Annual W ater Quality Conference
presentations provided
by teachers or staff
Number of students
present during the
presentation
1 1, W ere new outreach
materials created? Yes,
No; Status.
See BMP 3
IFiNAL NCTo On of Hudson
April I9, 2
Page 22
Council of Govermnents and
Lenoir Rhyne UrnuiversiConference
Anal Water Qualmpublic
to provide outreach and p
Participation. Staff will conduct
the annual regional conference for
continued education targeting
local government officials,
municipal staff, local buss public.
educators, and the general
1. Provide one
presentation about one
of the six NPDES
Minimum Control
Measures at each
annual conference. A
different MCM will be
presented on each
year.
Permit Years 1-5
at conference..
Evaluate Pollutants Sources and Audiences 1 wally 1. - 2. Number of
g' 1. Evaluate following target pollutant
Evaluate the target poeuatantsfa target pollutants: violations.
(litter, sediment, gray permit Years 1-5
ease, an mal operations, litter, sediment, gray
oils, gr su er water, fats, oils, Were SWMP revisions
underground storage tanks, P ease, animal needed to address
fund sites, chemicals, illicit grease,
operations, target pollutants or
discharges, illegal dumping, nderground storage audiences,
improper disposal of waste), tanks super fund sites,
sources, and associated target chemicals, illicit
audiences (residents, businesses, discharges, illegal
scbools, construction industrial, dumping and improper
commercial, farms, general dis osal of wasteo
development community, g 2. Evaluate the 2. Annually
public, and municipal employees)
following target
likely to have significant Permit Years 1-5
stormwater mp
acts and why they audiences: residents,
were selected. Th s evaluation is businesses, schools,
looking at target and ences that construction act vita,
are creating pollut on to allow the commercial, farms,
educa
Town to correctly focus cation development
d
efforts in those area, community, general
public and municipal
employees.
q, Evaluate Public Education and Outreach BMPs•
FINALNCTo nofHdon
April 19,2021
page 23
-
components of outreach through
merest and feedback.
10. W ebsite 1. Did the website
established
1. Maintain and update 1. Annually need revisions Yes,
Maintain the already
nvey the Stormwater program No; Status.
website designed to co
nformation on the Permit Years 1-5
program's message. The Town munici al
existing P
webpage will convey the website. Annually 2. Was annual self -
,importance of water quality and astaffwill assessment uploaded
2.'
link to the WPCOG Stormwater m�PanOand update Permit bears 1-5 to website? Yes, no;
webpage will be placed on the the WPCOG Status;
Town's website. The WPCOovide Stormwater web page
Stormwater webpage will p the MS4 Did links and/or
list the by: posting
educational resource l mks, contact information
Self -
compliant procedures, Stormwater Annual Self- need to be updated?
Assessment, verifying
regulations, stormwater permit yes, No; Status;
all links and contact
information and good information. information are
housekeeping current/active, posting Were new/current
the current year fliersfliers added to site?
Yes, No; Status.
The municipal
Stormwater webpage
will also have the
current SWMp,
Stormwater ordinance,
and annual assessment
3. Set a hit counter
order to monitor
engagement.
11.
Education Regarding Illicit Discharges
3
permityeazs ]-5
;. Report the
of hits.
F1N EiL NCTo On of Hudson
April N, 2021
Page 24
to munic P
businesses, citizens and schools
about the hazards associated with
Illicit discharges, illegal
dumping, and improper disposal
of waste.
employees in illic t
d scharge detection
A elimination.
2. Distribute material
2. See
(generated from BMp
3) to target audiences
I(municipal employees,
schools, businesses,
and cit zens).
during the enforcement
process.
$otline
This hotline will function as a
way for citizens to contact the
Town to report illicit discharges,
stormwaterlpost construction
issues, outreach questions and
Iconcerns, and MS4 related
concerns.
3. Continuously
permit Years 1-5
1. Establish a hotline l . Permrt
number for stormwater
complaints and
nformation.
s ecific 2. perm
2.Identify p
staff members who
will serve as hotline
Year 1
2. See
3
3. Number of citizen
nteractions during
enforcement.
1, Was hotline
established; Yes, No;
Date of establishment.
2. Was staff member
identified; Yes or No.
FINAL NCTo on of Hudson
April M 2021
page 25
type of complaints, permit years 1-5
concerns and
nfor nation related to
each call.
purpose of the call,
type'/measure the call
was about, date it
occurred, and
municipality of the
caller will be recorded. 4 Annually,
4. Train stormwater
hotline staff in general
stormwater awareness, Perndt Years 1-5
complaint call
Protocols and
appropriate contacts
for referral and typical
stormwater issues.
5. Publicize contact
5. Conunuuu�.y
information on the perm t Years 1-5
Town and WPCOG
stormwater webpages
as well as the town of
Hudson facebook
13. Litter Management
phone calls received
by typelpurpose of
call.
receive training? Yes,
No; Status.
5. Nmnber of nowu�
calls received overall.
F3NALNCTo 06ofHuds�on
April 19, 2021
page 26
Create an educational outreac
outreach materials wil
flyer that focuses on the impacts be created and
of litter on water quality, runoff
quality, and how it impacts the distributed to
government buildings
environment as a whole. These
each event
materials will be distributed at and at outr
cleanu
Town Hall and handed out at 2. Stream p
activities will be
public outreach events. utilized to educate
ants during participants on the
Educate particip of impacts of litter on
stream cleanups on the impacts Pa
litter to stormwater runoff and water bodies
SBMP 19
2. See BMP 19 2. ee
FiNALNCS000605 SWMP
Town of Hudson
April19,2021
Page 27
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
ram: The Town has been supportive of efforts in the
un College, Early
In reference to MS4 Permit Self Audit Report —Public Involvement and Participation, Permit Citation
II.C.2.a.VolunteerComa tyInvolvementFrogcommunity
service
projects
provide oppo unity for community
past and plans to grow the effort in the future. The location of Caldwell Co m
College High School and the Advancement Academy P form and surveyls, along with the use of the
owder Creek is located on the campus of all the schools listed above. The
completed
within Hudson. Little Gunp e reporting swill be comp
committee to gather public input. Stream clean-uP
Town of Hudson will establish a hot/ ne, ttee to will be announced through social media.
ex st ng WPCOG W ater Resource Cornet and public forums
on an annual basis. All events, programs,
implementation of a Publinot eerequirements.
This SWMp identifies the minimum elements and mp Tribal and local public
Program that complies with applicable State, public evolvement and
participation e implement and report the following P
The Town of Hudson will manage, P
participation BMPs.
14. Aotline for Public Input
Provide a mechanism for public
input on stormwaterissues am rough
the stormwater pxog
util zing the stormwater hotline
(BMP 12).
5 Web based form reporting
Provide an onl ne form for public
input and stormwater reporting
via the WPCOG website. This
will create an add t °nal way for
1. Stormw 1. See
�BNIP 12) sball
nclude a public input
component and/Or
record public input
cornmentslconcerns.
1. Establisn a w��
based complaint/
reportinglinput form to
be housed on the
permit Year 1
1. See BMP 12
1, Was the omme ,�«:
established? Yes, No;
Status.
FINAL NCS000605 SWMP
Town of Hudson
April 195 2021
Page 28
concerns, as weu as rav
the stormwater program.
i6, Social Media Ou___trea=h —
on 2. Use the form to
record and track
responses, nputs,
issues, and concerns
for metre reporting.
purpose of each
question, report, or
comment will be
documented to allow
for evaluation.
;. Ma nta n the web
based
complaint/reportinglin
put form on the
WPCOG website.
Zvent PromotiOn
Uti
perm t Years 2-5
3. Connnuuu°,y,
permit Years 1-5
1. Utilize the exrscmg
1.
Permit
questions, reports, alld
comments submitted
via the form.
3, Were revrsrons to
the web form needed?
Yes,No; Status.
1. Tot ber of
posts on the Town of
Hudson Facebook
page related to the
stormwater prow am.
FJN,kLNCS000605 SWMp
Town of Hudson
April M 2021
page 29
Provid ae meo ah n sm for pubnc
nput and participation via
regional meetings on stormwater
issues and the stomrwatex
program. Typically, this
committee is hosted by the
WPCOG once a quarter. This
committee also encourages
municipal interconnectivity
regarding water quality within the
region.
l , participate in
quarterly Water
Resource Committee
meetings, which are
open to the public, for
discussion of water
quality issues within
thexegion.
Topics discussed w ll
be recorded for annual
reporting.
.Quarterly meetings 1. Number of attendees
at each meeting.
pe mit years 1-5
and Evaluation Annually 1. Number of surveys
IS 1, Public survey 1, Create andcompleted.
Provide a mechanism for public
to sure s an annual t years 1-5
a survey
input by creating survey too be housed on Perm
engage the public and gauge the WPCOG
public interest in stormwatex
stormwater website
issues and the stormwater once a year, open to
program. The survey will be feedback for a total of
taking in responses/input on the 4 weeks The survey
program as a whole , covering
e and BMP will also be linked on
each minimum measure the Town of Hudson's
that refers to this survey. website.
Responses/results of
the survey will be
analyzed for reporting
and evaluation.
FINAL NCTo n of H d on
April 17, 2021
Page 30
19. Stream Cleanup
Provide votumcC'for ongoing citizen Participation
through stream cleanup activities.
If a safely accessible stream with litter/debris
an excess of built up
cannot be located, or built up litter
will not take enough time to
clean, stream side educational
as an
activities will be providedsupplement. These
educational
educational activities will focus
on educating Participants on water
quality and have the opportunity
for hands on activities involving
water bodies.
1. Hold stream cleanup
efforts by engaging
groups to conduct
stream cleanup
activities in
appropriate areas. The
events will b t
promoted by he Town
and WPCOC, with a
focus on civic groups.
1.
Permit Years 1-5
For the Town of
Hudson the stream
cleanups will focus on
Gunpowder Creek
and/or water bodies
that feed into it to help
uprove water quality
and provide personal
awareness for
2. Provide all matena
for sffeam cleanup
activities (i.e. gloves,
trash bags, and trash
pickers) hosted by
2.
Permit Years I-5
1. Number of stream
cleanup events held;
Number of stream
cleaTRIP participants;
Number of flash bags
filled.
2. Number of stream
cleanup materials
distributed.
FINALNCTo tin of H dso
Npril 19, 20 I
Page S
WPCOG will publicize permit Years 1-5
the event (hosted
TCOG) to the public
to gather volunteers
for stream cleanup
efforts to assist in
public awareness and
involvement. The
event will be posted on
the WPCOG website,
The Town website,
and flyers will be
distributed at Town
�---- 4. Annuauy
4 if streams do not
have adequate litter
Permit years 1-5
available for cleanp
supplement or replace
stream clean-up time
with outdoor
educational activities
3. Was the event
publicized? Yes, No;
Status;
Number of part cipants
per event.
4. Numner ui
supplemental act vit es
held;
Number of participants
n supplemental
activities;
FINALNCTo nofHudso
April 19, 2021
Page 32
HAR
GE DETECTION AND ELIMINATION PROG
pART 7: ILLICIT DISCRAM
e Detection and Elimination (IDDE
The Town had not developed written procedures for
MS4Inspect on Report for the Town °f Hudsono Illicit Discharge ..areas likely to have illicit
Permit Citation II.D.2.a. IDDE Pr In response the Town will locate priori illicit discharges and trace sources,
mplementing an IDDE Program. ram.
discharges, conduct routine dry weather outfall inspections, identify
of an illicit discharge, and evaluate and assess the IDDE program
Illicit Discharge
eliminate the source(s) action Report for the Town o Town has adopted and
t Citation ILD2.b. Legal Anthont}' rovidethe
The Town will also, in response to the MS4 sP regulatory
mechanisms that p
Detection and Elimination (IDDE)> Per m
to the MS4. the MS4
will maintain a d ernf o bit ,licit sand discharges ance and ther re
legal authority P of the map is in question and the Town
The City of Lenoir provided a map of the Town of Hudson's outfalls and MSC locations dunng
the accuracy In the future the
Inspection; however the map was developed in ties ( c Storm Sewer System Refi
to facilitate any MS4 act vit es (ILD.2. (permit Ref: 3.4.1 BMP 20)
did not use the map late MS4 within Permit Years 3 thr°ugh 5 ( Procedures
the comp or maintain written
Town will be Mapping weather screening
permit cy Weather Flow Program). Within the Stormwater
In the last p cle, the Town d d not conduct dry quarterly, Data such as
fox dry weather field activity
ILD.2.d. Dry weather screening q GIS.
Manag acted outfall, and photos of outfall will be recorded n
ement Plan a schedule is to be created to conduct dry roach to Illicit
date screening occurred, location of insp Pas
has taken a reactive approach
D,t e.P A list of violators were provided to DEQ
The Town of Lenoir, on behalf of the Town of Hudson, in the P
Discharge investigations with no wnttI procedures di ale, as stated
of the cases did not have a documented resolution (II.D2.f•) t
dating back to 2111; t Gy
however a major ty proactive stance will
DE Plan to establish written Procedures. A p
s unclear if any Of the violations
were
e i the Town of Hudson. Within the new
below, the Town will befaadopting application to track and document IDDE cases. This will allow the
be initiated with the use °a areas basGIS ed on historical data. illicit discharge and illegal
Town to identify priority
al staff and the general public to identify
0 orn'..res. Previously, no
Further, the Town will train Municipal es and
dumping 2 & h.). Educational materiaam l will be available to help educate
n through the use of educational outreac public abort hazards as
with illicit discharges
training had been administered (u-D' general p
public empl°Pees, businesses, and the g e portal or by phone;
the improper disposal of waste. through a webpag P hone number,
h nts of any kind could be subm tted to the Towni The stormwater hotline Pill e
Public comp unication was not publicized (Ii.D )' e areas of this plan, portal.
A
however the line of comet COG p
as menrioned n the Public education and outreach and Illicit disc erg
established on the WP an ems l tool on the WPCOG webpage.
COG website. A link from the Town' website will lead to the
citizen can make a complaint via hotline number or through
rt and ean
Disch
manage, implement, document, repofollowing illicit
discharge age
ram which shall, at a minimum, include the
The Town of Hudson will develop,
Detection and Elimination prog
detection and elimination BMPs.
FINALNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 33
20.
Map
1. Update existing maP I
Develod mainta n a to nclude open
municipal storm sewer system
channels and storm
stormwater
map including drain information and
conveyances, flow direction, flow, direction. This
major outfalls, and the waters of data will be collected
the United States receiving through a mixture of
stormwater discharges. The map
laced onto an arc -online preexist ng map data
will be p following its
map to make it multi -use and validat on), as well as
easily accessible for stortnwater field work based off
or IDDE issues. public Works and the
Planning Departments
Recommendation and
known information.
f MS4 mapping will be
completed each year (miles of
pipe type of pipe, number of
SCMs, number of outfalls, flow
direction located, number of
conveyances mapped
re
receiving bodies located/marked).
Maintain Legal Authority
21. —
1.
PennitYears 1-5
2. Add new
infrastructure to map
as new construction
occurs, updated on an
2.
Permit Yeazs 1-5
1, Was the map
updated Yes, No;
Status.
Was at ]east 20% of
the MS4 area mapped?
2, Was new
infrastructure added to
the map: Yes, No;
Status
gl]L'ALNCS000605 SWMP
Town of Hudson
April 19, 2021
page 34
(Section 7 of Town of Hudson
Phase 11 stOrmwater ordinance) in
order to maintain the legal
authority to prohibit, detect, and
eliminate illicit connections
and
discharges, illegal dumping
SPintills
o the MS4, including
forcementprocedures and
actions. Update ordinance if
required.
ordinance and update
f revision is required. Permit Years 1-5
Revisions will require
council re -approval.
22. IDDE Plan
Establish a written IDDE Plan to
detect and address illkcitand
discharges, illegal dumping
any non-stormwater discharges
identified as significant
contributors of pollutants to the
MS4.
1. Develop
IDDE Plan to define
the procedures of
dentifying, tracking
and processing illicit
discharges, illegal
dumping and
sI gnificant contributors
of pollutants to the
MS4. Submit IDDE
Plan to DEQ for
approval.
the ordinance needed?
Yes, No; Status,
developed? Yes, No;
status;
Date draft planis
submitted to DEQ for
approval.
F31bALNCTn dnofH dMP
April 19, 2021
Page 35
processes defined n
the IDDE Plan and
what is required by the
IDDE ordinance.
See BMP 27
3. Implement/Enforce 3. See BMP 27
3.
the IDDE Plan and
IDDE Ordinance.
23, Location of Priority Areas 1. Were priorityareas
L Annually, located? Yes, No;
Establish and maintain procedures I. Use MS4 map
likely to locate outfalls near Status,
areas l ke
for locating priority high pollution risk Permit Years 1-5
have illicit discharges. A high Number of Priority
areas. As BMP 20 is
priority area is an area that has a being completed, areas added upon
high chance of stormwater priority areas will be revision.
pollution potential: Areas with established. The
known dry weather outfall priority areas will be
flows/violations, repeat offenders, e-evaluated on an
business/commercial areas, annual basis to add
industrial areas, and businesses additional high priority
with high pollution potential. areas should they be
found or new ones
develop.
Dry Weather Ootfall Inspections Permit Year 11. Were procedures
24' 1. Establish a . 1
weather (no and the schedule
Perform regular dry outfall procedure to divide the established Yes, No;
rain inpreviousprevious hours) Town and create a Status.
inspections to proo actively identify hedule for dry
illicit discharges and illicit scections for
connections. The Town will be weather insp
broken into 5 sections, with at known outfalls.
2 Annu�ly 2. Number of dry
least one section e(20 )being 2, Implement dry weather inspections
inspected each p year, The
weather inspection completed;
inspections will consist of the rocedures. permit Years 2-5
currently known outfalls and P Number of potential
expanded with the progress of
Date inspections illicit discharges (from
BMP 20. occurred, location of dry weather flow)
inspected outfall, and identified.
photos of outfall will
be documented-
FIT,,'-kLNCs000605
nofHudson
April 19, 2021
Page 36
25 Illicit Discharges and Trace Sources __
Establish procedures to track and 1. Establish procedures 1. See BMP 27
to track verified
documentI1liritDischarge discharges and trace
investigations. sources.
intain and Implement IUUr
-
Maintain and hoPlement the
IDDE Plan to detect and address
illicit dischatges, illegal dumping
and any non-stormwater
I discharges identified as
significant contributors of
pollutants to the MS4.
Ma
26.
2. See BMP 27
cr
-� areas 1. Armuauy>
1. Seen p
likely to have illicit
scharges � BMP 23)• Permit Years 1-5
di
2. Investigate and 2. See BMP 27
Enforce IDDE issues.
3. Evaluate and assess 3. Annually
Che IDDE Permit years 1-5
plan/program —
Identify where
improvements can be
made based on data
collected.
Changes must be
approved by DEQ
from the previously
approved IDDE Plan.
See BMP 27
2. See BMP 27
1. Number of illicit
discharges found in
priority areas.
2. See BMP 27
3, Were revisions to
the IDDE PI an
needed? Yes, No;
Status.
FINALNCS000605 SWMP
Town of Hudson
April 19' 2021
Page 37
DDE Tracking 1 permit year 1 1. was the IDDE
tracing sheet
Staff will create a mechanisthmefor track ng sheet foDE developed? Yes, No;
tracking and documenting illicit tracking IDDE Status
date(s) an illicit dischazge, violations, recording
connection or illegal dumping who made the Date IDDE sheet was
was observed, the results of the complaint, location of developed.
investigation, any follow-up of complaint note prior
the investigation, the date the IDDE violations,
investigation was closed, the
status of the
issuance of enforcementonictionsolators. investigation and
and identifying actions taken. 2. Number of verifie
2. Record illicit
2. Continuously, IDDE issues-
discharge/connection
permit years 1-5
and illegal dumping
reports/investigations
on the IDDE tracking
sheet.
Differentiate staff
discovery from citizen
rePorting to allow for
review of outreach
program.
3. Upon mvesuga.,...-,
enforce Illicit
Discharge/connect on
and Illegal Dumping
violations to ensure the
responsible
party/violator remedies
verified illicit
3.
permit Years 1-5
3. Number of
violations/enforcement
actions issued;
Number of
violationslenforcement
act inns resolved.
FINAL NCTo n of Hudson
April 19, 2021
Page 38
maintain a list of permit Years 1-5
chronic violators, as
applicable. Updated on
5. Evaluate and assess
the IDDE tracking
sheet — Identify here
mprovement can be
made based on data
collected, problems
encountered and
needs. Evaluation of
the sheet will be done
on an annual basis to
find shortcomings with
the IDDE program
should they be
Zg, Staff Training
Train municipal staff and report
contractors to denlifyt p
illicit discharges,
connections, illegal dumping and
spills.
a
permit Years 2-5
1. Idenhry sraii
members and/or
contractors that are
likely to observe an
llicit discharge, illicit
connection and illegal
violators identified.
5. W ere revisions to
the IDDE tracking
sheet needed? Yes,
No; status
1. See BMP 11 1. See BMP 11
F'INALNCTo�ofH dson
April 19, 2021
Page 39
events to educate staff
and contractors in
identifying and
reporting illicit
discharges, illicit
connections, illegal
dumping, and spills.
Tra Wings will have a
sign n sheet to track
the names of trained
individuals.
29, IDDE Educator 1. See BMP 12
1. See BMp 12
ro re staff 1. Train hotline
Establish apPiat
p contacts in IDDE
contacts for field inquiriesawareness, complaint
regarding IDDE education, call protocols, and
outreach and complaints. During
IDDE enforcement, an outreach appropriate contacts
for referral. 2. See BMP 12
approach to 'raise awaroblematic 2. Utiliz ng social
why the violation s P d e °2. See BMP 12
i
will be taken (See BMP 12). The media anthae
hotline will also function as a WPCOG webp g
to IDDE publicize contact
mechanic forresponding
the public.
b i information for IDDE
questions from the p reporting
es, illegal dumping and spills. The mechanism al
34416 ID AE Reporting b appropriately trained
Permit public and staff to report illicit dis ed o provide rapid responsey
Ref. Measures fox the p and ball be managed D
public? to facilitate reporting C
ersonnel- B Annual R@Po
A Schedule for Metric
Hip Measurable Goal(') ! Ixn lamentation
No%. Description of BIVLP
30, IDDE Reporting
Hotline p, See BMP 12 1. See BMP 12
provide a hotline for the public 1. Utilize the hotline
and municipal staff to report illicit (B IDDE repW 12) to receive
reports.
FI',NttLNCS000605 SWMP
Town of Hudson
April 19,2021
page 40
es, illegal dumping and 2. Train hotline staf to
discharg differentiate between
Spills. illicit discharge
complaints and
stormwaterlpost-
construction
complaints. The staff
Will also be trained to
keep adequate recor ds
of the calls for metrics. 3. See BMP 12
3.P ublicize Hotline by 3. See BMP 12
including the phone
number on educational
materials. Post the
hotline number on the
Town and wPCOG
websites and shared
via social media
accounts.
31. IDDE Reporting W eb-based Reporting Form ee BMP 15 1. See BMP 15
1. S
Staff will establish and maintain a sewebfobm for
ased
web -based form reportingwhere IDDE
complaints/reports can be entered IDDE reporting.
and sent to the appropriate
reporting individual. Publicize the
reporting tool in education
outreach materials as well as on
the Town of Hudson webshe.
32 IDDE Reporting Efficiency 1. See BMP
1, See BMP 27
Staff will provide a sapid response A. Use the hIDDE eetonce
to all complaints received. Staff
tracking
will record the response dates and to tralck time oished f 27)
summary of results to improve
IDDE program and tracking sheet complaint, site
i to nt and
type of comp
all
enforcement/resolution
FINAL NCTo 0n of Hudson
April N, 2021
Page 41
2. Evaluate response �>Lu
t me. Work to
m nze response Permit Years 1-5
imi
t me to reported issues
and record what is
causing those issues to
be fixed in later
terations of the plan.
ITrack the times
elapsed between when
an IDDE incident is
reported, and when it
2. Average response
time.
FINALNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 42
PART g: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
the Town of Hudson relies upon the NmthCarolina
omeet a
Of 1973 as a qualify ing alternative prog
In accordance with 15A NCAC 0Ac .0153,
Sedimentation Pollution Control Act (SPCA)
e
Pollutants n stormwater runoff from construction cons�ction activity that
portion of the NPDES Mties that
S4 Permit requirements for construction site runoff control measure .
SPCA requirements include reducing p to one acre, and includes any
result in land disturbance of greater than or equalox implemented by NCDEQ in non -
Program common plan of development that would disturb one acre or more. The state SPC
is part of a largerMown, delegated to a county,
Program is either delegated to a city
delegated areas.
Alternative Program Components for Construction Site Runoff Control Program
Table 16: Qualifying _� i _ . __m a, a P.ntity ar Par
�p� m ted SPCA
3.5.4 uirements.
The Town of Hudson also implements the following BMPs to meet NPDES MS4 Permit req
33. Municipal Staff Training
Fdocumemation
nicipal staff who receive
m the public on the
s for referral and
of construction
ff control comp
L Train municipal 1. See BMP 50
staff on proper
handling of
construction site runoff
control com la" s. 2 Continuously,
2. Ma nta n a list of
tca ned municipal staff Permit Years 1-5
who have reported
construction run-off
ssues.
1. See
2. Number of
construction run-off
sues reported by
municipal staff.
Date trained staff
reporting list was
FINAL NCS000605 SWIvIP
Town of Hudson
April 19, 2
Page 43
Vleaos r�r•e�'thehotl ne, and
Utilize the survey,
the online form to give citizens
metbods of responding to how
construction runoff is being
managed. The surveyhw" ask
they
questions regarding:
unoff in the
view construcho th think hould be
Town, what. they hi upon u d
caged to imp believe
problems, and where they
there should be more focus within
the program.
35. W ante Manage=
L. Use survey l�j°
1 g) to obtain feedback
about public
perspective about
construction runoff in
2. Administer the
survey. The survey
will be linked to on the
WPCOG stormwater
webpage and the Town
of Hudson website.
3. Utilize report ng
form (BMP 15) that
will allow citizens and
the development
community (separately
distinguished) to write
concerns and report
construction runoff
to report concerns
about construction
runoff issues via the
online form on the
Town and WPCOG
websites and social
2. See BMP 1
2. See VIP 18
3. See
1. Develop an
ordinance that
addresses construction
siLe waste.
15
1
4. See
15
fl
t Y ear 1 1. Ordinance
1 Pernv developed: Yes or No,
Status.
F3NAL1�CS000605 SW1vIP
Town of Hudson
April M9 U21
page 44
2.Orinance aooprGu=
Construction Site Runoff Control Bws developed 2. Permit earl d
Yes, Status.
2. Adopt
Require construction site he ordinance through
operators to control waste cause council approval. BN1P 50
3. Se
construction Site t that T quahty' 3. SeeBMP 50
e
adverse imp 3. Train mun cipal
staff on identifying
and reporting
construction waste 4 were any revisions
violations. 4 Annually
adopted to the waste
4. Maintain
ordinance (if revisions permit years 2-5
management ordinance
are needed). made? Yes, NO;
Status.
5. Enfor d niroe ante 5.
using the tracking
sheet to track and
document
construction site
waste concerns and
FFN.aCNCS000605 SW�'lp
Town of Hudson
April 19, 2021
Page 45
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
MS4 Inspection Rep al Authority, "At the time of inspection, the Town
Report for the Town of Hudson —Post-construction Site Runoff Control Program
ls
lement the post -construction site runoff controls plans,
Implementation Statue, Perm t C ord n�jGe to imp Legal rather than the Town of Hudson
was utilizing a Caldwell County
to conduct inspections ofpost-construct on cto ontrols." The
program. The ordinance authorized Caldwell County, rather
request information, and enter private Property
adopted a sto mwater Ordinance, hich authorizes herant ng the
Town of Hudson has developed and
than the County protective
covenants (II.F.2.e J is be included.
to administer the aforementioned items. W ithm the ordinancelanguage
Town of Hudson the ability to require deed restrictions and p and within the
�6.B.1, 2, Along with the
WPCOG, n inventory of projects will be established (BMP a private
Contracting Staff theser-annually and certified by p
municipal limits, this is n response to Permit Citation II.by St of the latest audit (20ce .
list proactive inspections will be adm ministered Upon non-compliance, enforce
memnet mecacthanism will
inventory P to ensure SCM functionality
engineer annually Practice in years past, but now the Town will have a GIS track ng
be taken, not a common P compliance as 2.i.).
proactively enforce to obtain comp
of Lenoir, on behalf
MS4 Inspect on Report for the Town of Hudson — le
Post -construct Site Runoff Control Program SCMs t in the permitted area specifically to
ty
sth'
Implementation Status, Per ntt Citat on: ILF.. Nutrients tees withn the MS 1
3.care receiving discharge
of the Town of Hudson had not designed or constructed any
reduce nutrient loads. At this time it is uncleaz if the co-p
into the nutrient sensitive waters. m lement and enforce a program to address
than or to
This SWMP ment and redevelopment projects that disturb greater
tdentifies the minimum elements to develop, P er common Plan of developmentrn
or
stormwater runoff fio o ects less than one acre that are part of a laxg
one acre, includ ng P 7 u
are
uali impacts utilizing a combination of structuraapd ensure adeqate long-
ntrol
sale, that are located with n the Town of Hudson and discharge nto the MS4. These elemen s
designed to minimiazne�o tnon-structural BMPs appropriate for the commumty>
Ivleaswes (SCMs)
term operation and maintenance of SCMs. lements the following
the Town of Hudson imp ost-construction
the NPDES Phase II MS4 p where
In accordance with 15ANocA�0 eq oementsawhich satisfy pps) in the MS4 area(s)
State post-constructio rogr is
are implemented,
as Qualifying Alternative Programs) (Q
site control
they are
FINALNCS000605 SWMP
Town of Hudson
April 19,2021
Page 46
Town of Hudson Watersheds
�— Watar SupPtY Watershetls. �.
Legend
Hudson Townlmits P te�teE AreaWSIV
„G Wj r Roatla
e n Hudann ETJ :.Road$
3 -'ll i mLimt Stearns !,Rivers N^
LenoirGKY Lnrl s A
O I hs Mounteln Town Lirrais
O Is
0
The Town of Hudson has existing requurements including the presents of a Qualifying Alternative
Pxogram(s) n a portion of the Town limits. The Qualified Alternative Program is the Lake Hickory water
supply watershed Protected Area WS-IV. To ensure complianceeth thecNP act on standards post-
constructionprogram requirements the Town of Hudson appcat p
throughout the Town Limits, including the area that is located �lementat on pehBMP 38 B 3-4, and are
are to be adopted as local ordinance(s) per BMP 38.B.1 •and imp
summarized in Table 19 below.
FINALNC40000605 SWMP
Town of Hudson
April 19, 2021
Page 47
_ n.nRram Elements
....� e r the Host constructionprogram are Provided in table ��• """
gfNALNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 48
Post Construction Site Runoff Control BMPs 1. Continuously
1. Track number of Permit hears 1-5
[mplement standardized tracking, low density and high
documentation, inspections a t pile density plan reviews
reporting mechanisms to comp erformed.
appropriate data for the annual P
self -assessment process. Data 21 Cont nuously
shall be provided for each Post- 2. Track nu aner d high Permit Years 1-5
ua" m low density
Construction Q �' g density plans
Alternative Program being
ov
plemented as listed n Tables 3pN aintain a current 3. Continuously
18 and 19. inventory of low Perm t Years 1-5
density projects. and
constructed SCs
including SCM type or
low density acreage,
location and last
inspection date.
4. Track number of
SCM
inspections
performed.
5. Track number of
low density
inspections performed.
6. Track number and
type of enforcement
act ons taken.
37. Qualifying Alternative Program
uirements are applicable to a portion
The QAP re 9_ nr.9inance is being adm
4. Continuous')
permit Years 1-5
5. Conttnuuun�y
pest years 1-5
permit Years 1-5
reviews perlormed for
]ow density and high
density.
2. Numoer m y.u..
approvals issued for
low density and high
3. SummarY of number
and type of SCMs
added to the inventory;
and number and
acreage of low density
projects constructed.
4. Numoer c
inspections.
5. Number of low
density projects
nspected
6. Number and type o
enforcement act ons
issued
fiilfill bothorequu ments e Phase II Post-
EINAC:NCT won ofHud on
April 19, 2021
page 49
38 phase H Post -construction Stormwater Ordinance
ted and will J. Tra n staff (field
The Town has adop and office) in
maintain in effect the Phase II Stormwater Ordinance
Stormwater Ordinance, which procedures and
gives the Town legal author ty to nforcement actions.
review designs for new
development and redevelopment, 2. Enforcement of e
Phase II Post -
to ensure adequate Stormwater construction
controls, to request information,
to perform inspections on private Stormwater Ordinance
to ensure compliance.
property, and to perform other Should the correct
compliance activities related to processes and order
this measure. not be followed, a
The ordinance references the
DEQ BMP Design Manual as the betissued to address ce of violation ill
source of standards to be used m the violation.
selecting, designing, evaluating,
and maintaining structural and
1. See tsrvxr '�
2. Continuously,
permit Years 1-5
1. See BMP 50
2. Num— b 4ces of
violationsissued;
Number of Civil
Citations issued;
Number of still in
progress of abatement
at time of annual
report.
FIN AL NCTo n of H d on
April17,2021
Page 50
Plan Review and AppCova
39,
Review plans for all new
development and redevelopment
sites that will disturb greater than
or equal to one acre (including
I projects less than one oacre ltan of e
part of a larger comet P
development or sale).
1. Review p
and submittal to Permit Years 1-5
documents annually
determine if items need
to be added or
Pa
All required submittals (as
defined by the plan review
procedures) must be received by
the reviewer before the issuance
Of a Certificate of Occupancy (per
development). Should the
procedures not be followed, a
notice of violation and stop work
ordered in
h thell be Town'suordinance and ce
SOP.
modified. 2, See BMP 36
2. Review plans for all
new development and
redevelopment sites
that will disturb greater
than or equal to one
acre. This is including
less than one
acre that are part of a
larger common plan of
development or sale.
This requirement also
applies to Federal, State
and Local Government
The Town of Hudson requests
that the County holds the
Certificate of occupancy on all
developments that fall under
stormwater regulations within the
Town. The CO is issued
until
all stormwater requirements
(designs, submittals, and
inspections) are saUsf ed and the
Stormwater Administrator
approves the issuance.
prolc���� 3, See
3. Maintain the sheettt g
SCM Inventory
Said sheet tracks all
required submittals,
relevant information,
and all projects within
theTown that have
one through (and/or
the
are going through )
stormwater review
procedure.
1. We Ur ce ce—anges to tha
procedures/submittal
documents needed?
Yes, No; Status,
6Y�
3.
FiN.�-NCS000605 SWMP
Town of Hudson
April 19, 2
page 51
40. Operation and Maintenance greet. Ensure that each 1. Continuous projects with O&M
The Operation and Ma tire" cc project has an approved tans that received their
(O&M) agreement requires O&M Agreement and Perm t Years 1-5 CO.
owners of structural BMPs to O&M Plan prior to CO,
perpetually maintain and operate
to the O&M to be included in the
BMPs according project checklist and
plan submitted during the plan required prior to CO.
review process and require Each O&M agreement
submission of annual inspection
ualified will include a
a
reports written by q requirement for annual
professional. Each O&M inspections,
agreement shall include an
enforcement component defining
the actions the eTown
canfoDtake
dif
the O&M P
1. See BMP 36
41. Recordation ocess shall
1. Ensure each project 1. See BMP 36
The plan review pr
has recorded deed
include verification that
permanent legal mechanisms are restrictions
rotectivescovenants in
in effect ensuring the project is P
effect to ensure
built consistently with its
Tans. This will be development activities
approved p h the submittal of will be maintained
verified throng consistent with the
an engineer's certification and roved plans (low
providing an as -built. These must p density
and high
be received and accepted to ro ects . 2. See BMp 36
approve the issuance of that 2 Ensure that each 2. See BMP 36
projects CO. SCM and associated
A recorded deed restriction or
maintenance access
areas are recorded in a
protective covenant, along with
an access easement is established permanent easement to
through recordation. Recording
both guarantee access for
boththe access easement and inspection and
b
restricons'
Certificate Of maintenance of the
FINALNCTQ OnofH dson
April 17, 202]
Page 52
Table 20: Post Construction site Runoff Control BMPs
Permit 3.6.4» Inspections ands nforcement
inspection and enforcement authority, standards and procedures to: (a) Conduct post
Ref. Measures to maintain insp or a Temporary Certificate of Occupancy.
construction inspections prior to issuing
Certificate
a surety f Ord to guarantee compliance pliance with the approved plan(s),
:Alternatively, the project owner may p c Ensure annual
(b) Ensure that the project has been constricted n accordance with the approved plan(s), ( )ce
inspection ofeach permitted SCM to ensure complianceroects at least oiiceodnring the permine n� nand (e) Regmte
Agreemem (d) Ensure inspection of low density p 1
that inspections be conducted by a qualified professional.
C D
A B
B1YSR schedule for Annual Reporting
Measurable Goals) Metric
No, Description of BMP Im lementation
42, Inspection and Enforcement 1. Number of pre -CO
After project completion, but 1. Prior to issuance of a 1. COnt nuously inspections completed
prior to issuance of a certificate of CO, a qualified Town
occupancy, an inspection will be representative shall Permit Years 1-5 Number of repeat
completed by a qualified perform an inspection inspections required.
professional to ensure the project on all project SCMs to
has been constructed according to ensure compliance. If
the plan/design. Following
corrections are
approval, annual inspections by a required, then follow
qualified professional will be up inspections will be
completed. Low density projects performed until the
will be inspected once in a permit SCM and project site is
term to monitor potential compliant prior to the
impermitted expansion and apply issuance of CO.
enforcement if violations are 2. Number of SCM
found. 2. Staff will perform 2. Annually,
inspections of all SCMs
inspections completed.
(both government and Permit Year 1-5 Number of failed SCM
non -government) ins ection
within the Town. 3. Number of qualified
3. Owner shall have a 3. Annually licensed professional
Qualified Licensed inspections completed
Professional perform an Permit Year 1-5 with documentation
SCM inspection in received.
accordance with the
O&M Agreement and Number of SCMs
DEQ SCM manuals under annual inspection
once a year. enforcement.
FINALNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 53
4. Annually 4. Number of low
ost Construction Site Runoff o4�Co d snspectum density inspections
of pYears 1-5
20/ of low -density Peru done; Number of low
density violators found.
projects each year (See Number of low density
BM? 36 for inventory). enforcement actions
Docnmen----- tat1OII—L,owDensity
Ensure tr and records are
maintained on low density
projects to ensure t nop°ages
inspection, imp
can be determined, and corrective
actions taken. $nsure
informational materials are
available on the WpCOG website
to guarantee accessibility outside
of office hours. Through traclang
and inspections chronic violators
will be identified. 20 oect dthe ow
per
density sites will be nsp P
year.
1. Maintain low
density project list to
nclude existing sites.
2.Inspectthe
completed low -density
projects to ensure the
projects have not
expanded into a high
density classification
thus needing a SCM.
Documentation — gigh Density
44. �--
3. Pro tv d e ce ud ational
material to the general
public about low
density developments:
during the issuance of
zoning permits,
distributed through
mailings, posted on
social media, and
handed out at events.
See
2. See
3.
36 1. See BMP 36
42 42. See BMp 4'.
PennitYears 1-5
3. Number of low
density educational
matey als distributed.
FLN AL NCTo� of Hudson
April 19, 2
page 54
Post Construction Site Runoff Col, Mai i an 1. See BMP 36
A. SeeBMP 36
Ensure tracking and records are inventory of all
maintained on projects to ensure
developments and
that upon granting of final CO
inspection redevelopments
and follow-up ins p (public and private) with SCMs. Up
impervious overages can be date
determined and corrective actions inventory as projects
taken. Ensure informational are reviewed,
materials are available online tt ved, and
guarantee accessibility of approconstructed. Continuously 2. Number of high
office hours. Through track ng density informational
and inspections chron c violators mprovide
e° ado developers permit Years 1-5 materials distributed
will be identified. about high density
development. At a
minimum, hyperlinks
will be maintained on
the Towns web page
directed to the
Ordinance and to the
BMP Design Manual.
Printed materials will
be distributed (but not
limited to): during the
issuance of zoning
permits, distributed
through mail, digitally
posted on social
media, and handed out laced on the
at events. 3. Items p
3. Establish links to all 3. Annually vvebpage: Yes or No,
ordinances, manuals, Status
Permit Years 1-5
policies, checklists, laced
design standards, Were items rep
and/or other materials with current versions if
on the WPCOG revisions were
website. required? Yes, No;
F'INAI-NCTo nofH d on
April I9, 2021
Page 55
45. Fecal COhfnrm Reduction 1 Annually
Protective measures have been 1. Maintain Pet
Waste e tot Years 1-5
established throughthe onent o adoption of reduce the amount of Permit
the pet waste comp et waste.
Phase 11 Stormwater Ordinance. p 2 Continuously,
2. Develop and
The majority of the Town of supply septic tank
Hudson's wastewater is manageds aterials awarenes
Permit Years 1-5
however m
via a sewer system — through
tanks within to the County
there are still septic the pipCOG septic
the Town that could become
hPollution. tank program. These
An outreach approach
source of fecal will be flyers will be used to
rai
taken to assist in reducing this Septank Pollution
e awareness of
pollutant and raise awareness. and septic
1. DidPet waste
Ordinance require
revisions? Yes, No;
Status
2, Number oT septw
tank flyers distributed.
g'gN tL NCTo n of Hudson
Npril M9 V21
Page 56
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING pgpggAMS
good housekeeping strategy for the
provides a comprehensive pollution prevention and prevention and good housekeeping rs
This SWMP p ark and open
lementation of sevenrequired programs, which bons such
address the
Town of Hudson municipal facilities and operations. Pollution p
accomplished through the ImP ollutant runoff from municipal operations such as p
ultimate goal of preventing or reducing p
space maintenance, fleet and building maintenance, new construction and land disturbances, an
stem maintenance.
municipal storm sewer syoperations includes the following Programs:
Pollution prevention and good housekeeping for municipal
1 Municipal Facilities Operation and Maintenance Program
2. Spill Response Program
;. MS4 Operation and Maintenance Program
eration and Maintenance Program
4, Municipal SCM Op
5 Pesficide, Herbicide and Fertilizer Management Program
6 Veh cle and Equipment Cleaning Program
7. pavement Management Program good housekeeping
report the pollution prevention and
manage,ho leroc and rep In response to the inefficiencies
The Town oe Hf da°n TabWillle below for each required program. P
BMPs as sp ed an inventory
olluted
identified in the MS4 Inspection Report, Permtt Citations ILG.2.a., the Town had maintain
ossible ollutexs will be established.
of rmwataar>mo�ti A lb ttoha�e otPeterminped wlnch facilities were at risk to genera e p
s
An O & M p g1 o ram will be established. (BEQ
ro the SWMP and in Permit YeeahOn oan O & M pto g ate (II.G2 b' asdequired per A ex
the acceptance of
ns ected annually'
Furthermore, the in facilities and SC were not being P orated in the
Incorp
Municipal SCMs were not inventoried to date; but "it is believed that the Town of
(II.G2.b. c. & g•) owned structural stormwater controls"
and maintenance for facilities
Hudson does not have municipally op
O & M pTOan > staff will be trained to determine appropriateG.2.e
n thus area. The Town of Hudaqnnnces (II did n)t perform street
and SCMs. To date staff had po training catch basins and stormwater convey
maintenance, including cleaning
Lenoir lid not evaluate BMP s based
II G.2,d states that "The City of on their pollutant removal" in
public parking lot maintenance, Several of the BMPemo°al in address
rhesethis
reference to streets, roads, and and ma retaining procedures that focus on pollutant
developing, adoptang, s 59-62 address thus prior lack of evaluation and
issue by u rements for street/parking lot
impervious areas. Permit Reference: 3.7.7, BMP' schedules and req 60.B.2
program implementation. BMP 59 focuses on setting and collecting litterldebris, with BMPthe oils,
BMPs 60 and BMP 61 focuses on minim z ng 62 addresses procedures for clean ng
sweeping. outreach program. BMP the developed standard spill procedures as
working in part as a community utilizing
fluids, and debris thatc and from Car accidents by
necessary according
FINALNCS000605 SWMP
Town of Hudson
April 19, 2021
page 57
ns ection, and maintenance of said system. BMP
In the audit, II.G.2.e addresses the prior lack of maintenance of the Town's storm sewer system, Permit
Reference, 3.7.3, BMP's 48,51 focus on the tra n ng, p
49 develops the required o&M plan which defines procedures/schedules, BMP io trains MP 52ners on
oninspection
the maintenance on the system with documentation.
the correct procedure, BMP 51 focuses on inspection along with its documentation; and BMP 5
addresses the audit problem itself by performing
Previously, the use of pesticides, herbicides, and fertilizers in municipal facilities was not well tracked or
manag appropriate
(minimal) usage.
esl as stated in Il.G.2.h. Permit Reference, 3.7.5, BMP 55 focuses to ensure all staff using
Pesticides, herbicides, and fe contractotilizers ocert ficat ou as wall and
copiewins of ermits of both municipal
BMP 56 focuses on track ng
staff and contractors.
E.G.2.1 addresses inconstant/lacking training for municipal employees in regards to good housekeeping
ro rams required by the permit.
and pollution practices. This is addressed in: 47.B.5, 48.B.4, SO.B.1 BMP, 54.B.55 SS.B.1, 57.B.2, 58.b. ,
and o and n pra .Each of these BMPs focusing on each of the 7 p g
correct waste disposal and cleaning of municipal
side t the problem, addressing training, protocol,
II.G.2.J addresses a lack of measures regarding
vehicles/equipment. BMP 57 focuses on the washing
requirements, and options for municipal vehicle operators. BMP 58 focuses on the other side of the issue,
ensuring that vehicle maintenance facilities are correctly d sposing of waste and that perm ttng is
Cnllnwed to ensure MS4 compliance.
F'INALNCSTOo00nofH don
Apri119,2021
Page 58
in BMFS 1. See BMP 47
Pollution prevention and Good Housekeep all
1. See BMP 47
st be 1. Insp
An cl & M Planemnen ed, and municipal facilities to
developed, imp determ ne which
maintained for each mumciPal facilities require an
facility with the potential to O&M plan to be
generate stormwater pollution.
developed. All
These plans will define the facilities will be
expectations of the facility in nspected once per
regards to stormwatex MS4 emut term.
regulations. Each municipal P licable facilities
facility in which this is applicable App
will implement an O&M plan. will be inspected
The implementation of a plan annually (See BMP
all binding 47 2, permit Yeaz 1 2. Number of facility
entails signing a legally 2. Develop an O & M O&M plans
document that defines the parry plan for each developed.
charged with ensuring that the
s correctly maintained municipal facility with
facility the potential to
and documentation of the enerate storinwater
maintenance is adequate. The gollution. Each plan
documents will also define the P
procedures in how the facility will will define required
be maintained to reduce the risk procedures per
ollution. The applicable facility to
of stormwater P O&M plans inspect, maintain and
facilities requiring evaluate the facilities
will be inventoried through BMP
47. Should the facility maintain risk of stormwater
ollution. 3. permit Years 2-5 3.O Numbers facility
and/or store vehicles, washing Implement the O&M plans
procedures will be defined in the written O & M Plan implemented.
facilities O&M plan. (per applicable
facility . 4. See BMP 47
4. Enforce and inspect 4. See BMP 47
the facilities to ensure
compliance with the O
& M Plans.
Municipal Facilities the existing 1. Permit Year 1
1. Is the facility list
verification complete:
The municipal facilities operation lit1. f Verify Yes or No, Status.
plan will ensure list of facilities is
and maintenance p correct by using tax
the facilities are being cords and field visits. Date of completion
managed/maintained in a way that re
does not negatively impact water
quality. The facilities will be
maintained in a scheduled and
weltdefined manner by
FINAL NCS000605
of H dson
April 19, N0
Page 59
performing rollfine nspecnons. ��
a facility is subject to SPCC
requirements, then specific
nspection procedures will be
completed per the SPCC
requirements. At the time
developing this Sl h' .
of Hudson does not own a facility
that would fall under SPCC
requirements. Should one be re-
evaluated and SPCC criteria are
met, it will be managed as such.
48. Spill Response
Z. Use tax aara aiiu
facility visits to
determine if the
facility has a Potential
pollutant and/or spill
risk (Make note of
3. Pertorm�a�.�«�
nspectionsto ensure
the Town is following
good housekeeping
measures.
2. Permit Year 1
3.
Annually
permit Years 1-5
4. Document and
correct issues found
during inspections. if
a facility is subj ect to
SPCC requirements,
then ensure the correct
documentation is in
place for compliance
with the
regulation/requirement
5 t Tar]] llluu��iy�
facility staff on proper
stormwater awareness
and good
housekeeping
methods.
4_ Annually
Permit
Years 1-5
1. Develop a written
spill response
procedure plan for
each facility that
requires one.
1. Permit
p
with potential
ollutants/spill risk.
Number of potential
SPCC facilities.
3. Numoer ui �a��-
inspected.
Number of SPCC
permitted facilities
4. Number of
corrective actions
taken
(SPCC permitted
facilities andnou-
SPCC facilities).
5. See BMP 50
1 1, Were the procedures
created for all facilities
that require one Yes,
No; Status summary'
gT]yAL NCO won of Hudson
Npri119,2021
Page 60
Spill %program for
facilities and operations that store
and/or use materials that pose a
spill risk. The program will be
designed in away that tracks
potential polluting facilities as
well as defining the
procedures/materials required for
spill response in those facilities.
The definition of reportable spills
will be written in"following
eachfacility
spill response plans
§143-215.85,
�usekeeping BMPS,
2, hvplement the spill 2. permit Year 1
response procedures
an ( er facility).
3. Mainta n spill 3. Annually
response procedures in
permit Years 1-5
response to problems
that may arise from
implementation of spill
�— staff
4. Train facility
on
spill response
5. Respond to spills as
fey occur and manage
the spills following
established spill
procedures.
Reportable spills (per
§143-215.85) will be
reported to DEQ.
BMP 50
4. See
5.
PermitYeazs 1-5
response plans
3. Nurn of spill
response procedure
plans that required
revisions.
See BMP 50
5. Ntuvber of non -
reportable spills.
Number of spills
reported to DEQ.
FINALNCTo On of Hudson
April i95202]
page 61
49. MS4 Operation & Maintenance ( 1 Was the MS4 O&M
1. Develop an O&M 1 Permit Year 1 plan developed: Yes
An O & M Plan must be plan to define the or No, Status.
developed, implemented and P required procedures to
maintained to follow the
hedul
requirements of the MS4 NPDBS s erformemaintenance
Phase II Stormwater collection P
system permit. Asa component of and evaluations of the
improvement stor nwater collection
this plan, a capital imp system The plan shall
component will be included to cover inspection
assist in prioritizing parts of the
MS4 as determined by the MS4 schedules, standazd
inspections (BMP 50) The O&M documentation, and
staff res onsibilities. permit Year 7 2. W as the O & M
plan must also be submitted to 2 2 Submit the plan approved by
DEQ for approval. developed O&M Plan DEQ; Yes or No,
to DEQ for approval. Status.
Date of submittal to
DEQ.
3 permit Years 2-5 3. Was the O&M Plan
3. Implement the implemented, Yes,
written O M Plan, No; Status.
4. Cont nuously, 4. Number of MSl ted.
4. Administer the inspections comp
O&M Plan (See BMP permit Year 2-5
51 & 52).
PItY'ALNCTo nofH don
April 17, 2�21
Page 62
51.
Provideprovide tS¢ tS4 ra n ng to
1. Hold MS4 training
events to educate staff
municipal and contracted staff to on MS4 topics listed in
minimize pollutants in the the referencing BMPs&
stormwater collection system, Train all current
prevent unnecessary damage and municipal staff on
wear on the system, increase
awareness of stormwater issues, Irermd essyeaofPri
procedures on how regardless of prior
Iand show the p to br ng them
to deal with stormwater related trainingup to current
issues. standards. This will
cit reoccur at the
beginning of each new
permit cycle
These tra n ngs will prevention,
outreach, discharges> Pollution p
outreach, how to respond to IDDE
or post construction issues, spill
prevention and response
procedures, municipal facility
requirements, construction runoff,
Post construction ordinance and
procedures, pesticide and fertilizer
management, IDDE Plan
procedures and requirements,
IDDE ordinance, angod
bousekeeping procedures,
Inspection
I . perm t Year 1
The topics covered and
number of participants
will be recorded at
2. Train any newly
h red staff during
permit years' 5 or
were not previously
trained on stormwater
best management
2. Permit Years 2-5
1. Number of train ngs
held;
Number of personnel
tra ned.
2. Number of trainings
held;
Number of personnel
tra ned.
F3N.AL NCTo qp of Hud on
April 19, 2021
Page 63
inspections to ensure cSCMs and
lines, non-functioning
drainage inadequacies are
dentified.
52. MS4 Maintenance
nfrastructme (pipes,
major outfalls,
stormwater
conveyances, and
basins) to ensure
functionality.
MS4 inspections to ensure
cjogged fines, non -function ng
basins, and drainage inadequacies
are repaired, if the municipality
cannot reasonably maintain issues
with MS4 infrastructure found in
a permit yem, it can be contracted
out to a qualified licensed
professional if the Town chooses
to do so. The town will utilize
public works resources to
ma nta n the Sol infrastructure;
or the issue willbe included in the
Towns capital improvement
project list, and appropriately
prioritized depending on the
1. 'on 1. Nuf catch
mber o
basins and
conveyances
Permit Years 1-5 inspected; Number of
conveyance issues
found reported.
1.Inspe 1'
municipal catch basins
and conveyances on an
annual basis and/or
upon report of
maintenance being
2 M� �e will be
completed upon
fording through
nspection or receiving
reports of MS4
nfrastructure in poor
condition.
2.
Permit Years 1-5
1. See BMP 51
cleanings/maintenance
actions performed.
FINALNCTo dn6ofHudso
April 17, 2021
Page 64
No. operation & Maintenance (O & M)
53, Municipal SCMs Op 1, See BMP 36 1. See BMP 36
The maintenance procedures and 1. Maintain an
inventory of the Towns municipal inventorexisting o Tof owned
SCMs will be kept up to date. SCMs with
However, at the time of
information
developing this SWMP the Town including type= Yew
built, date of last
does not currently have a
municipally owned SCM. Should inspection, and
maintenance actions.
the Town of Hudson need to 2. Cont nsly 2. Were any
install one following expansion, 2 Develop and uoumunicipal SCM
these procedures will be followed. maintain SCM O&M's developed?
Operation and yes, No; Status,
Maintenance Plans for
each Town -owned
SCM.
3. 3. See BMP 54 3. See BMP 54
Review/Update
SCM inventory as
necessitated
by new Town
develo went.
54, Municipal SCMs 1. Is the SCM list
operation 1. Verify the existing 1. Permit Year1 complete: Yes or No;
The municipal SC o a will list of municipal SCMs Status (Location and
and maintenance program
water structures itype to be
ensure the storms correct by visiting determine documented).
are being managed maintained in the typeland tes tcond condition.
away that does not negatively Use
mpact water quality. The SCMs Use aerial photography
wiTown records to
ll act
maintained n a scheduled in conjunction with
and well-defined manner written determine SCM
in its O&M plan, location/ ownersh p.
FINALNCS000605 SWMP
Town of Hudson
April L9,2027
Page 65
Table 21: Pollution Prevention and Good Housekeeping BMYs
T
aY the time of 2. Maintain Inventory
this SWMP the Town of municipally owned
does not currently have SCMs. Add all newally owned SCM. SCMs as they aree Town need to install constructed.ing expansion, theses will be followed.
3. Perform annual
inspection and
maintenance of
municipally owned
SCMs to ensure the
operation and
maintenance plan is
being followed.
4. Document and
correct issues found
during inspections.
5. Should a municipal
SCM be installed,
Training on the
maintenance of the
SCM and its function
shall be held.
55. Pesticide, Herbicide and Fertilizer Training to Staff
2. Continuously 2. Did the inventory
require any municipal
Permit Years 1-5 SCMs to be added
Yes, No; Status.
Total number of
mun cipal SCMs
3. Annually 3. Number of
municipal SCMs
Permit Years 1-5 inspections done.
4. Annually 4. Number of issues
identified/recorded;
Permit Years 1-5
Number of corrective
actions/repairs taken.
5. See BMP 50 � 5. See BMP 50
FIN.�lLNCS000605 SWMP
Town of Hudson
Apri] 19, 2021
Page 66
Measures to mrmmv�� •�--
quality impacts from the use of
landscaping chemicals. The only
staff wbo will be allowed to apply
pesticides, herbicides, or
fertilizers will be certified
individuals who use methods that
minimize the amounts used.
--
staff on the use,
storage, and handling
to get officially
certified. The training
will include methods
of using mine
Ichemicals to reduce
harmful effects,
especially around
SCM maintenance.
Herb tic d aue d Fertilizer
Ensure compliance with permits
and certifications for the
administering of pesticides,
herbicides and r rtilizer
to
less�me
application of product
impactful to stormwater runoff.
Only certified landscapers/
Isprayers are theories applying
pesticides, herbicides, and
1. Maintaining copies
of
licenses/certifications
of
all staff and
contractors who use
landscaping chemicals.
57. Vehicle and Equipment Cleaning
Prevent or rvnn"
Contamination of Stormwater
Runoff from all areas ent Cleaning'
Vehicle and Equipment
Wash water can be directed to the
sanitary sewer or to vegetated
areas. Where cleaning operations
cannot be performed as described
ahnve and when operations are
P
ennitYears l-5
1. Es andard
Operating Procedure
for containing and
disposing of vehicle
and equipment wash
water. The procedures
will be defined
through the facilities
1. See
1. Number of certme
municipal personnel.
1.
FINAL NCTown of H d on
April 19. 2021
Page 67
performed in the vicintty ox a
storm drainage collection system,
the drain is to be covered with a
portable drain cover during
cleaning activities. Any excess
standing water shall be removed
and properly handled prior to
removing the drain cover. OR
another acceptable method is
installation of a SCM to capture
and treat the wash water runoff.
vehicle pollut on
prevention trahling to
3. Wash all muntctpat
light vehicles, Town
emergency vehicles,
and equipment using
an established method
listed under this BMP,
or utilize a commercial
carwash facility that
contains and treats
wash water where
applicable.
4. Record washing
procedures. Upon
facility inspection
(BMP 47) verify that
documentation is being
kept ensuring
compliance and said
documentation shows
the facility is
following the best
management practices
defined in their O&M
5g. Vehicle and Equipment Maintenance
Measures to ensure that the waste
generated by vehicle maintained
at municipal facilities (included,
but not limited to, oils, any
running fluids, batteries, belts and
other non -fluid vehicle waste) is
being disposed of properly.
2. S7BIVP0ly
Permit Years 1-5
1. Ensure the Town
has obtained a NPDES
industrial permit for all
subj ect municipal
facilities/operations
2. Perform waste
inspections during
facility inspections
lSee BMP 47).
4. See BMP 47
1. Permit Years 1
2. See BMP 47
3. Number of vemcte
washings performed;
Was vehicle washing
completed per this
BMP? Yes, No; Status;
Provide quarterly
nvoices from
commercial carwash if
utilized.
4. See BMP 47
1. Log of industrial
permits and status.
Number of municipal
industrial permitted
2. See BMP 4
FiNALNCS000605 SWMP
Town of Hudson
Apr l 19, 2021
Page 68
able 21:Pollution Prevention and Good Housekeeping BMPs
3. Provide routine 3. See BMP 50 3. See BMP 50
pollution prevention
and waste management
training to staff.
Permit 3.7.7: Pavement Management Program
Ref. Measures to reducepollutants'sn 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 13 C D
BMP Schedule for Annual Reporting
No. Description of BMP Measurable Godlls) Im lementation Metric
59, Street and Parking Lot Sweeping
Measures to reduce pollutants in 1. Street/curb and 1. Annually 1. Total number of
stormwater runoff from gutter sweeping will lane miles swept.
municipally owned streets, roads, be done to reduce road Permit Years 1-5
and parking lots within the pollutants in runoff
permittee's corporate limits. As with a focus on high
the Town of Hudson does not priority areas prone to
have a regular street cleaning buildup or higher
service, streets will be chance of conveyance
swept/cleaned annually. To damage/hindrance.
supplement this, an outreach 2. Track 2. Continuously 2. Number of high
approach and right of way conveyances/inlets that priority cleanings
conveyances/inlets with frequent have frequent Permit years 1-5 done.
issues will be prioritized. problems with
pollution to prioritize
their maintenance.
FINALNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 69
Table 21: Pollution Prevention and Good Housekeeping BMPs
3. Develop and
3. Continuously
3. Number of street
distribute educational
pollution flyers
flyers regarding street
Permit Years 1-5
distributed.
runoff pollution to
help supplement street
cleanings.
60.
Litter Management
Collect litter in public areas and
1. Public waste
1. Continuously
1. Number of full time
parking lots to reduce negative
receptacles located on
employees
impacts on water quality.
municipally owned
Permit Years 1-5
responsible;
parcels and within
Number of trash bags
Town right of ways are
used.
serviced on an as
needed basis.
2. All other litter
2. Annually
2. Number of litter
collection is performed
pick up events
on an as -needed basis
Permit Years 1-5
utilizing available staff
Weight of trash
or community
collected/disposed of
volunteers.
for each event
(pounds);
Number of staff and/or
volunteers.
61.
Leaf Collection
Implement measures to control
1. Leaves are collected
1. Annually
1. Cubic yards
leaves and debris within the
with vacuum -style
collected during
municipal Town limits (to include
equipment from
Permit Years I-5
November to January.
all properties). The Town of
November I" through
Hudson picks up leaves on an
January 31 s'. Outside
annual basis from November la`
those months citizens
through January 31 s`.
can bag their leaves to
be collected with trash
pickup.
62.
Vehicle Pollutant Management
Measures to prevent and minimize
1. Train first
1. Annually
1. Number of first
contamination of stormwater
responders for
responders (staff)
runoff from vehicle pollutants
minimizing, collecting
Permit Years 1-5
trained and date of
following an accident,
and disposing of fluids
paining.
and other vehicular
pollutants following an
accident.
FIN.4LNCS000605 SWMP
Town of Hudson
April 19, 2021
Page 70
Table 21; Pollution Prevention and Good Housekeeping BMPs
2. Continue equipping
2. Annually
2. Amount of materials
the first responder
used/replaced in kits.
vehicles with spill kits
Permit Years 1-5
and material
containment tools.
3. Public Education to
3. Annually
3. Number of vehicle
include infonnation
pollution educational
about vehicle leaks in
distributed materials
Permit Years 1-5
materials handed out,
and other educational
resources.
4. Illicit Discharge
4. Annually
4. Number of vehicle
enforcement for
IDDE issues
significant vehicle
Permit Years 1-5
documented; number
leaks from parked cars.
of vehicle IDDE issues
enforced/corrected.
FINALNCS000605 SWMP
Town of Hudson
Apri] 19, 2021
Page 71