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Home My WebLink AboutNCS000502_Trinity Draft SWMP_20210804 Draft Stormwater Management Plan City of Trinity NCS000502 July 30, 2021 DRAFT Table of Contents PART 1: INTRODUCTION ........................................................................................................................ 1 PART 2: CERTIFICATION ........................................................................................................................ 2 PART 3: MS4 INFORMATION .................................................................................................................. 3 3.1 Permitted MS4 Area ..................................................................................................................... 3 3.2 Existing MS4 Mapping ................................................................................................................. 3 3.3 Receiving Waters .......................................................................................................................... 4 3.4 MS4 Interconnection ..................................................................................................................... 5 3.5 Total Maximum Daily Loads (TMDLs) ....................................................................................... 5 3.6 Endangered and Threatened Species and Critical Habitat ............................................................ 6 3.7 Industrial Facility Discharges ....................................................................................................... 6 3.8 Non-Stormwater Discharges ......................................................................................................... 6 3.9 Target Pollutants and Sources ....................................................................................................... 7 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ..................................... 9 4.1 Organizational Structure ............................................................................................................... 9 4.2 Program Funding and Budget ..................................................................................................... 11 4.3 Shared Responsibility ................................................................................................................. 11 4.4 Co-Permittees .............................................................................................................................. 12 4.5 Measurable Goals for Program Administration .......................................................................... 12 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 14 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 17 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 19 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................... 24 PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 26 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ...................... 31 DRAFT List of Tables Table 1: Summary of MS4 Mapping Table 2: Summary of MS4 Receiving Waters Table 3: Summary of Approved TMDLs Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality 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 BMPs Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Table 17: Construction Site Runoff Control BMPs Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program Table 19: Summary of Existing Post-Construction Program Elements Table 20: Post Construction Site Runoff Control BMPs Table 21: Pollution Prevention and Good Housekeeping BMPs DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 1 PART 1: INTRODUCTION The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the City of Trinity will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent practicable. This SWMP identifies the specific elements and minimum measures that the City of Trinity will develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with the MS4 Permit number NCS000502, as issued by NCDEQ. This permit covers activities associated with the discharge of stormwater from the MS4 as owned and operated by the City of Trinity and located within the corporate limits of the City of Trinity. In preparing this SWMP, the City of Trinity has evaluated its MS4 and the permit requirements to develop a comprehensive 5-year SWMP that will meet the community’s needs, address local water quality issues and provide the minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated annually to ensure that the elements and minimum measures it contains continue to adequately provide for permit compliance and the community’s needs. Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along with any approved modifications of the SWMP, are incorporated by reference into the permit and become enforceable parts of the permit. Any major changes to the approved SWMP will require resubmittal, review and approval by NCDEQ, and may require a new public comment period depending on the nature of the changes. DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 2 PART 2: CERTIFICATION By my signature below I hereby certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4 Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit compliance and enforcement authority. ☐ I am a ranking elected official. ☐ I am a principal executive officer for the permitted MS4. ☐ I am a duly authorized representative for the permitted MS4 and have attached the authorization made in writing by a principal executive officer or ranking elected official which specifies me as (check one): ☐ A specific individual having overall responsibility for stormwater matters. ☐ A specific position having overall responsibility for stormwater matters. Signature: Print Name: Title: Signed this ____ day of 20____ . DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 3 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This SWMP applies throughout the corporate limits of the City of Trinity, including all regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits of the City of Trinity as of the date of this document. 3.2 Existing MS4 Mapping The current MS4 mapping includes location of storm structures, depth, type, and flow direction. Location of all outfalls is underway. The map is available to the public at the following address: https://www.trinity-nc.gov/index.asp?SEC=48ADD296-1DB3-4406-9920-B9F0392467B2 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 4 Table 1: Summary of Current MS4 Mapping Percent of MS4 Area Mapped 43 % No. of Major Outfalls* Mapped 30 Total *An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch) directly into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned areas a 12-inch diameter pipe or a drainage area > 2-acres. The City is in the process of updating its MS4 map, with an illicit discharge BMP to address the data gaps. 3.3 Receiving Waters The City of Trinity MS4 is located within the Yadkin Pee Dee River Basin and discharges directly into receiving waters as listed in Table 2 below. Applicable water quality standards listed below are compiled from the following NCDEQ sources: o Waterbody Classification Map o Impaired Waters and TMDL Map o Most recent NCDEQ Final 303(d) List DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 5 Table 2: Summary of MS4 Receiving Waters Receiving Water Name Stream Index / AU Number Water Quality Classificatio n 303(d) Listed Parameter(s) of Interest Uwharrie River 13-2-(0.5) WS-III Little Uwharrie River 13-2-1 WS-III North Hamby Creek 12-119-7-4-1 C Benthos (Nar, AL, FW) Hunts Fork 12-119-7-3 C Benthos (Nar, AL, FW) C – Class C (fishable/swimmable waters) WS III – Water Supply Watershed III Benthos (Nar, AL, FW) – Narrative standard, aquatic life, fresh waters 3.4 MS4 Interconnection The MS4 does interconnect with the statewide NCDOT MS4 and includes: a. The interconnection is receiving stormwater from the NCDOT MS4. The number of interconnections is unknown. b. The interconnection is discharging stormwater into the NCDOT MS4. The number of interconnections is unknown. c. The City of Trinity MS4 mapping does not identify interconnections with the NCDOT MS4. d. The City of Trinity MS4 mapping does not include NCDOT MS4 outfalls. 3.5 Total Maximum Daily Loads (TMDLs) The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map and list provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program has been implemented to address the WLA. Table 3: Summary of Approved TMDLs Water Body Name TMDL Pollutant(s) of Concern Stormwater Waste Load Allocation (Y/N) Water Quality Recovery Program (Y/N) Statewide Mercury N N No TMDLs have been approved within the MS4 area. The Statewide TMDL for mercury does not require any actions by the NPDES stormwater permittee because most mercury in stormwater comes from atmospheric deposition. DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 6 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endangered species and/or critical habitat are identified within the regulated MS4 urbanized area. Based upon a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Map and Listed species believe to or known to occur in North Carolina map as provided by the U.S. Fish and Wildlife Service, the species listed in Table 4 have the potential to occur within the regulated MS4 urbanized area. Of those species listed, Table 4 summarizes the species that may be significantly impacted by the quality of surface waters within their habitat. Table 4: Potential Federally Listed Species/Habitat Impacted by Surface Water Quality Scientific Name Common name Species Group Federal Listing Status Danaus plexippus Monarch butterfly Invertebrate Candidate Fusconaia masoni Atlantic pigtoe Invertebrate Proposed Threatened Notropis mekistocholas Cape Fear shiner Vertebrate Endangered Helianthus schweinitzii Schweinitz’s sunflower Vascular Plant Endangered Symphyotrichum georgianum Georgia aster Vascular Plant Resolved Taxon 3.7 Industrial Facility Discharges The City of Trinity MS4 jurisdictional area includes the following industrial facilities which hold NPDES Industrial Stormwater Permits, as determined from the NCDEQ Maps & Permit Data web page. Table 5: NPDES Stormwater Permitted Industrial Facilities Permit Number Facility Name NCGNE0700 Trinity Furniture, Inc. NCGNE0925 Packaging Corporation of America NCGNE1063 Fleet Painting Service, Inc. NCS000502 Trinity City-Small MS4 3.8 Non-Stormwater Discharges The water quality impacts of non-stormwater discharges have been evaluated by the City of Trinity as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. The City of Trinity has evaluated residential and charity car washing and street washing for possible significant water quality impacts. Wash water associated with car washing that does not contain detergents or does not discharge directly into the MS4 is considered incidental. However, these types of non -stormwater discharges that do contain detergents have been evaluated by the City of Trinity to determine whether they may significantly impact water quality. The City utilizes Public Education and Outreach and Pollution Prevention and Good Housekeeping BMPs to educate residents and municipal staff on the possible effects of detergents entering the surface waters. Street washing discharges are addressed under the Pavement Management Program in Part 10 of this SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the City of Trinity. DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 7 Table 6: Non-Stormwater Discharges Non-Stormwater Discharge Water Quality Impacts Water line and fire hydrant flushing Incidental Landscape irrigation Incidental Diverted stream flows Incidental Rising groundwater Incidental Uncontaminated groundwater infiltration Incidental Uncontaminated pumped groundwater Incidental Uncontaminated potable water sources Incidental Foundation drains Incidental Air conditioning condensate Incidental Irrigation waters Incidental Springs Incidental Water from crawl space pumps Incidental Footing drains Incidental Lawn watering Incidental Residential and charity car washing Possible Flows from riparian habitats and wetlands Incidental Dechlorinated swimming pool discharges Incidental Street wash water Possible Flows from firefighting activities Incidental 3.9 Target Pollutants and Sources In addition to those target pollutants identified above, the City of Trinity is not aware of other significant water quality issues within the permitted MS4 area. Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the likely activities/sources/targeted audiences attributed to each pollutant, and identifies the associated SWMP program(s) that address each. In addition, the City of Trinity has evaluated schools, homeowners and businesses as target audiences that are likely to have significant stormwater impacts. Table 7: Summary of Target Pollutants and Sources Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing Target Pollutant(s)/Audience(s) Litter Residential, Commercial, Schools Public Education & Outreach, Public Involvement & Participation Non-Stormwater Car Washing Residential, Commercial, Schools Public Education & Outreach, Public Involvement & Participation Street Wash Water, Municipal Pollutants Municipal Operations Pollution Prevention and Good Housekeeping DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 8 Sediment Construction, Commercial, Municipal Operations Public Education & Outreach, Construction Site Runoff Control, Post-Construction Site Runoff Control, Pollution Prevention and Good Housekeeping Fecal Coliform Sewer Leak, Failing Septic Systems, Pet Waste Public Education & Outreach, Illicit Discharge Detection and Elimination Illicit Discharge/Illegal Dumping/Improper Disposal of Waste Residential, Commercial, Industrial, Municipal Operations Public Education & Outreach, Public Involvement & Participation, Illicit Discharge Detection and Elimination, Pollution Prevention and Good Housekeeping DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 9 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure The City of Trinity Stormwater Program is implemented by the Stormwater Administrator and through the Public Services Department, both overseen by the City Manager. City of Trinity Stormwater Management System Organization Chart City Council City Manager Debbie Hinson Stormwater Administrator Marc Allred Public Works Superintendent Rodney Johnson Public Works Supervisor Scottie Cooper Public Works Technician Derek HensleyDRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 10 Table 8: Summary of Responsible Parties SWMP Component Responsible Position Staff Name Department Stormwater Program Administration Stormwater Administrator Marc Allred Planning SWMP Management Stormwater Administrator Marc Allred Planning Public Education & Outreach Stormwater Administrator Marc Allred Planning Public Involvement & Participation Stormwater Administrator Marc Allred Planning Illicit Discharge Detection & Elimination Stormwater Administrator Marc Allred Planning Construction Site Runoff Control Stormwater Administrator Marc Allred Planning Post-Construction Stormwater Management Stormwater Administrator Marc Allred Planning Pollution Prevention/Good Housekeeping for Municipal Operations Stormwater Administrator Marc Allred Planning Municipal Facilities Operation & Maintenance Program Stormwater Administrator Marc Allred Planning Spill Response Program Stormwater Administrator Marc Allred Planning MS4 Operation & Maintenance Program Stormwater Administrator Marc Allred Planning Municipal SCM Operation & Maintenance Program Stormwater Administrator Marc Allred Planning Pesticide, Herbicide & Fertilizer Management Program Stormwater Administrator Marc Allred Planning DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 11 Vehicle & Equipment Cleaning Program Stormwater Administrator Marc Allred Planning Pavement Management Program Stormwater Administrator Marc Allred Planning Total Maximum Daily Load (TMDL) Requirements N/A N/A N/A 4.2 Program Funding and Budget In accordance with the issued permit, the City of Trinity shall maintain adequate funding and staffing to implement and manage the provisions of the SWMP and comply with the requirements of the NPDES MS4 Permit. The budget includes the permit administering and compliance fee, which is billed by the Division annually. The Trinity Stormwater program is funded through the General Fund with an approximate 2021-2022 proposed budget of $91,175. 4.3 Shared Responsibility The City of Trinity will share the responsibility to implement the following minimum control measures, which are at least as stringent as the corresponding NPDES MS4 Permit requirement. The City of Trinity remains responsible for compliance if the other entity fails to perform the permit obligation and may be subject to enforcement action if neither the City of Trinity nor the other entity fully performs the permit obligation. Table 9 below summarizes who will be implementing the component, what the component program is called, the specific SWMP BMP or permit requirement that is being met by the shared responsibility, and whether or not a legal agreement to share responsibility is in place. Table 9: Shared Responsibilities SWMP BMP or Permit Requirement Implementing Entity & Program Name Legal Agreement (Y/N) 3.2.2 and 3.2.4 Outreach to Target Audiences, 3.3.2 Volunteer Opportunities Piedmont Triad Regional Council (PTRC) Y 3.6.5(b) On-Site Domestic Wastewater Treatment County Health Department N DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 12 4.4 Co-Permittees The are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000502 for the City of Trinity. Table 10 summarizes contact information for each co-permittee. Table 10: Co-Permittee Contact Information Co-Permittee MS4 Name Contact Person Phone & E-Mail Interlocal Agreement (Y/N) N/A N/A N/A N/A 4.5 Measurable Goals for Program Administration The City of Trinity will manage and report the following Best Management Practices (BMPs) for the administration of the Stormwater Management Program. Table 11: Program Administration BMPs Permit Ref. 2.1.2 and Part 4: Annual Self-Assessment Measures to evaluate the performance and effectiveness of the SWMP program components at least annually. Results shall be used by the permittee to modify the program components as necessary to accomplish the intent of the Stormwater Program. The self-assessment reporting period is the fiscal year (July 1 – June 30). BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Annual Self-Assessment Perform an annual evaluation of SWMP implementation, suitability of SWMP commitments and any proposed changes to the SWMP utilizing the NCDEQ Annual Self- Assessment Template. 1. Prepare, certify, and submit the Annual Self- Assessment to NCDEQ prior to August 31 each year. 1. Annually Permit Years 1 – 4 1. Yes/No Permit Ref. 1.6: Permit Renewal Application Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the NPDES MS4 permit. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 2. Permit Renewal Application Audit stormwater program implementation for compliance with the permit and approved SWMP and utilize the results to prepare and 1. Participate in an NPDES MS4 Permit Compliance Audit, as scheduled and performed by EPA or NCDEQ. 1. TBD – Typically Permit Year 4 1. Yes/No DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 13 Table 11: Program Administration BMPs submit a permit renewal application package. 2. Self-audit and document any stormwater program components not audited by EPA or NCDEQ utilizing the DEQ Audit Template. Submit Self- Audit to DEMLR (required component of permit renewal application package). 2. Permit Year 5 2. Yes/No/Partial 3. Certify the stormwater 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 expiration. 3. Permit Year 5 3. Date of permit renewal application submittal 3. Documentation Evaluate existing documentation methods to determine the best way to document implementation of all BMPs for annual reporting 1. Review existing documentation methods to determine if all reporting metrics in the SWMP are included 1. Permit year 1 1. Report number of documents reviewed and if any changes were made 4. Funding Assessment Perform a fiscal analysis and explore options to obtain adequate program funding to fully fund the stormwater program and meet all requirements of the permit. 1. Complete a fiscal gap analysis 1. Permit year 1 1. Report monetary value of gap 2. Determine available funding mechanisms and evaluate options 2. Permit year 1 2. Yes/No/Status 3. Select a funding mechanism 3. Permit years 2 3.Report funding mechanism selected 4. Implement funding mechanism 4. Permit years 3 4. Yes/No/Status DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 14 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM The City of Trinity will implement a Public Education and Outreach Program to distribute educational materials to the community or conduct equivalent outreach activities about the impacts of storm water discharges on water bodies and steps the public can take to reduce pollutants in storm water runoff. The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the City of Trinity is required to inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping and improper disposal of waste. Table 12: Summary of Target Pollutants & Audiences Target Pollutants/Sources Target Audience(s) Litter Residential, Commercial, Schools Non-Stormwater Car Washing Residential, Commercial, Schools, Municipal Operations Street Wash Water, Municipal Pollutants Municipal Operations Sediment Construction, Commercial, Municipal Operations Fecal Coliform Sewer Overflows, Failing Septic Systems, Pet Waste Illicit Discharge/Illegal Dumping/Improper Disposal of Waste Residential, Commercial, Industrial, Municipal Operations The City of Trinity will manage, implement, and report the following public education and outreach BMPs. Trinity has partnered with PTRC to implement public education and outreach and will establish a legal agreement to continue the partnership. PTRC provides television commercials and radio advertising, newspaper and print ads, brochures and flyers, curriculum guides for schools, movie theater ads, and promotional items with a logo. Table 13: Public Education and Outreach BMPs Permit Ref. 3.2.2 and 3.2.4: Outreach to Targeted Audiences Measures to identify the specific elements and implementation of a Public Education and Outreach Program to share educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The permittee shall provide educational information to identified target audiences on pollutants/sources identified in Table 12 above, and shall document the extent of exposure of each media, event or activity, including those elements implemented locally or through a cooperative agreement. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 5. Partnership with PTRC Continue to engage with PTRC for education and outreach initiatives that will be administered by PTRC. Initiatives will focus on residential, commercial, and school audiences. 1. Establish 5-year legal agreement with PTRC 1. Permit year 1 1. Yes/No/Status 2. Monitor PTRC activities to ensure partnership commitments are met 2. Annually, permit years 1 – 5 2. Report number and types of programming, topics, and total audience reached DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 15 Table 13: Public Education and Outreach BMPs Target pollutants will include those listed in Tables 7 and 12. 3. Review legal agreement to determine if target pollutants or audiences should be revised 3. Annually, permit years 2 – 5 3. Yes/No/Status and report if revision is required 4. Renew legal agreement with PTRC or develop alternate program 4. Permit year 4 4. Report date renewed, or alternate program established 6. City-Sponsored Events Distribute information on stormwater during at least one City sponsored event or festival a year (in person or virtually) 1. Develop or identify one informational handout for distribution at the event that covers a target pollutant or vehicle leaks 1. Annually, permit years 1 – 5 1. Yes/No/Status 2. Staff the event/festival chosen and document the number of handouts distributed 2. Annually, permit years 1 – 5 2. Report the chosen event and number of handouts distributed at the event Permit Ref. 2.1.7, 3.2.3 and 3.6.5(c): Web Site Measures to provide a web site designed to convey the program’s message(s) and provide online materials including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit and SWMP. The web page shall also provide developers with all relevant post-construction requirements, design standards, checklists and/or other materials. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 7. Stormwater Pages on City Website Continue to maintain the stormwater web pages with information regarding relevant ordinances, post- construction requirements, design standards, and educational information 1. Maintain the web pages - update any broken links, upload new educational material 1. Annually, permit years 1 – 5 1. Report the date the web page is reviewed and updated as well as what updates are made 2. Set a hit counter in order to monitor engagement and update annually 2. Annually, permit years 1 – 5 2. Report the number of annual hits DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 16 Table 13: Public Education and Outreach BMPs Permit Ref. 3.2.5: Stormwater Hotline Measures for a stormwater hotline/helpline for the purpose of public education and outreach. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 8. Stormwater Hotline A hotline will be maintained for citizens to ask stormwater questions and report stormwater issues. The hotline number will be advertised on the stormwater webpage 1. Establish and maintain hotline phone number and responsible party 1. Permit year 1 1. Yes/No/Status 2. Establish and train a responsible party to answer the hotline and direct calls 2. Permit year 1 2. Report the date of training and number trained 3. Train responsible parties in general stormwater knowledge, appropriate contacts for stormwater questions, and citizen opportunities within the stormwater program 3. Annually 3. Report the date of training(s) and number trained 4. Establish and maintain a tracking mechanism to document the number and type of calls received 4. Permit year 1 and annually thereafter 3. Report the number and type of calls 5. Publicize hotline in materials developed for the stormwater program and posting on stormwater webpage 5. Annually 5. Yes/No/Status and number of materials with stormwater hotline DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 17 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that complies with applicable State, Tribal and local public notice requirements. The City of Trinity will manage, implement and report the following public involvement and participation BMPs. Table 14: Public Involvement and Participation BMPs Permit Ref. 3.3.1: Public Input Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 9. Stormwater Pages on City Website Continue to maintain the stormwater web pages with information regarding relevant ordinances, post- construction requirements, design standards, and educational information (see BMP No. 7) 1. See BMP No. 7 1. See BMP No. 7 1. See BMP No. 7 10. Stormwater Hotline A hotline will be maintained for citizens to ask stormwater questions and report stormwater issues. The hotline number will be advertised on the stormwater webpage (see BMP No. 8) 1. See BMP No. 8 1. See BMP No. 8 1. See BMP No. 8 Permit Ref. 3.3.2: Volunteer Opportunities Measures to provide volunteer opportunities designed to promote ongoing citizen participation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 11. Partnership with PTRC Continue to engage with the PTRC to develop volunteer opportunities that will be administered by PTRC. Opportunities will focus on residential, commercial, and school audiences. Target pollutants will include those listed in Table 7 1. Establish legal agreement with PTRC 1. See BMP No. 4 1. See BMP No. 4 2. Monitor PTRC activities to ensure partnership commitments are met 2. See BMP No. 4 2. See BMP No. 4 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 18 Table 14: Public Involvement and Participation BMPs 12. City-Sponsored Volunteer Opportunities The City will provide one City- sponsored volunteer opportunity (in person or virtually) such as stream cleanups, volunteer monitoring, or Earth Day activities at least once a year. Residential, commercial, and school audiences will be targeted with special emphasis on civic groups, large employers, and large trade associations 1. Develop or identify one volunteer activity that addresses a target pollutant or pollutants 1. Annually, permit years 1 – 5 1. Yes/No/Status 2. Coordinate and host the activity 2. Annually, permit years 1 – 5 2. Report the event, target audience, and number of participants DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 19 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The City of Trinity will develop, manage, implement, document, report and enforce an Illicit Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs. Table 15: Illicit Discharge Detection and Elimination BMPs Permit Ref. 3.4.1: MS4 Map Measures to develop, update and maintain a municipal storm sewer system map including stormwater conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 13. Updates to MS4 Map Continue to update the MS4 map with information including stormwater conveyances, outfalls, flow direction, and receiving waters. Update the map annually with newly identified or constructed stormwater infrastructure 1. Continue mapping of system to identify all outfalls and flow directions in conveyances 1. Permit years 1 and 2 1. Report the percent of Trinity mapped and number of outfalls identified 2. Add receiving waters to the map 2. Permit year 3 2. Yes/No/Status 3. Develop process for collecting as-built data and incorporating into the existing map 3. Permit year 3 3. Yes/No/Status 4. When new conveyances/outfalls are located or constructed add them to the map 4. Annually, once BMP No. 13.1 is completed 4. Report if new outfalls were identified (Yes/No). If yes, report number identified during the permit year and during the permit term DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 20 Table 15: Illicit Discharge Detection and Elimination BMPs Permit Ref. 3.4.2: Regulatory Mechanism Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4, including enforcement procedures and actions. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 14. Maintain Legal Authority The City’s stormwater ordinance (“Universal Stormwater Management Program Ordinance” for the City of Trinity, NC Article 1: Sec-102) provides legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping, and spills into the MS4, including enforcement procedures and actions 1. Maintain and enforce IDDE ordinance 1. Continuously 1. Report if ordinance revision is required Permit Ref. 3.4.3: IDDE Plan Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4. The plan shall provide standard procedures and documentation to: a) Locate priority areas likely to have illicit discharges, b) Conduct routine dry weather outfall inspections, c) Identify illicit discharges and trace sources, d) Eliminate the source(s) of an illicit discharge, and e) Evaluate and assess the IDDE Program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 15. Maintain IDDE Plan Continue to implement the existing written IDDE plan 1. Maintain the written IDDE plan 1. Continuously 1. Yes/No/Status 16. IDDE Program Evaluation Yearly evaluation of IDDE program to promote continuance of effective components and improvement in 1. Evaluation meeting with Stormwater staff 1. Annually, in conjunction with annual self-assessment for permit years 1-4 1. Report any proposed changes DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 21 Table 15: Illicit Discharge Detection and Elimination BMPs areas that are lacking, as well as identification of chronic violators 2. Review of IDDE reports and identification of chronic violators, issues, and/or “hot-spot” areas 2. Annually, in conjunction with annual self-assessment for permit years 1-4 2. Report (a) number of potential illicit discharges found, (b) number of illicit discharges verified, (c) number of illicit discharges resolved/removed, (d) number of enforcement actions taken, and (e) number of chronic violators/“hot spots” identified 17. Outfall Inspections Perform regular dry weather (no precipitation in previous 72 hours) outfall inspections to proactively identify illicit discharges and illicit connections 1. Train inspections staff to perform dry weather outfall inspections and illicit discharge investigations 1. See BMP No. 19 1. See BMP No. 19 2. Perform inspections of 20% of outfalls as described in the IDDE plan 2. Annually, permit years 1 – 5 2. Report the number of outfalls inspected, and number of potential illicit discharges identified Permit Ref. 3.4.4: IDDE Tracking Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was observed, the results of the investigation, any follow-up of the investigation, the date the investigation was closed, the issuance of enforcement actions, and the ability to identify chronic violators. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 18. Tracking Spreadsheet A tracking system for observed IDDE violations and follow-on actions will be developed and implemented in order to identify “hot-spot” areas, chronic violators, and recurring issues (see BMP No. 3) 1. See BMP No. 3 1. See BMP No. 3 1. See BMP No. 3 2. Annually evaluate observed violations for chronic violators 2. See BMP No. 16 2. See BMP No. 16 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 22 Table 15: Illicit Discharge Detection and Elimination BMPs Permit Ref. 3.4.5: Staff IDDE Training Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities, may observe an illicit discharge, illicit connection, illegal dumping or spills. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping and spills. Each staff training event shall be documented, including the agenda/materials, date, and number of staff participating. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 19. Staff Training Provide training to educate City staff of indicators of potential illicit discharges/ connections and illegal dumping and the appropriate avenues through which to report suspected illicit discharge 1. Identify or develop staff training for public services employees 1. Permit year 1 1. Yes/No/Status 2. Train staff with Illicit Discharge & Detection responsibilities 2. Annually, permit years 1-5 2. Report number trained 3. Train staff with the potential to discover an illicit discharge during routine work activities 3. Annually, permit years 1-5 3. Report number trained Permit Ref. 3.4.6: IDDE Reporting Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained personnel. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 20. Stormwater Pages on City Website Continue to maintain the stormwater web pages with information regarding relevant ordinances, post- construction requirements, design standards, and educational information (see BMP No. 7) 1. See BMP No. 7 1. See BMP No. 7 1. See BMP No. 7 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 23 Table 15: Illicit Discharge Detection and Elimination BMPs 21. Stormwater Hotline A hotline will be maintained for citizens to ask stormwater questions and report stormwater issues. The hotline number will be advertised on the stormwater webpage (see BMP No. 8) 1. See BMP No. 8 1. See BMP No. 8 1. See BMP No. 8 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 24 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153, the City of Trinity relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 as a qualifying alternative program to meet a portion of the NPDES MS4 Permit requirements for construction site runoff control measures. The SPCA requirements include reducing pollutants in stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre, and includes any construction activity that is part of a larger common plan of development that would disturb one acre or more. The state SPCA Program is either delegated to a city/town, delegated to a county, or implemented by NCDEQ in non-delegated areas. Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Permit Reference State or Local Program Name Legal Authority Implementing Entity 3.5.1 - 3.5.4 State Implemented SPCA Program 15A NCAC Chapter 04 NCDEQ 2 The City of Trinity also implements the following BMPs to meet NPDES MS4 Permit requirements. Table 17: Construction Site Runoff Control BMPs Permit Ref. 3.5.6: Public Input Measures to provide and promote a means for the public to notify the appropriate authorities of observed erosion and sedimentation problems. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 22. Municipal Staff Training Train municipal staff who receive calls from the public on the protocols for referral and tracking of construction site runoff control complaints. 1. Train municipal staff on proper handling of construction site runoff control complaints. 1. Annually 1. Number of staff trained 2. Document the number of violations identified and referred to NCDEQ 2. Annually 2. Report number of violations referred 23. Stormwater Hotline A hotline will be maintained for citizens to ask stormwater questions and report stormwater issues. The hotline number will be advertised on the stormwater webpage (see BMP No. 8) 1. See BMP No. 8 1. See BMP No. 8 1. See BMP No. 8 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 25 Table 17: Construction Site Runoff Control BMPs Permit Ref. 3.5.5: Waste Management Measures to require construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to water quality. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 24. Establish and Maintain Legal Authority Develop and implement an ordinance to require construction site operators to control waste 1. Pass code 1. Permit year 2 1. Yes/No/Status 2. Maintain legal authority 2. Continuously, after ordinance is adopted 2. Yes/No/Status 25. Contractor Education Communicate waste management requirements to construction site operators 1. Identify/develop fact sheet to share at pre- construction meetings 1. Permit year 3, after ordinance is adopted 1. Yes/No/Status 2. Add fact sheet to website 2. Permit year 3, after ordinance is adopted 2. Yes/No/Status 3. Distribute fact sheet during final review meetings or pre- construction meetings 3. Permit year 3, after ordinance is adopted 3. Number of fact sheets distributed DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 26 PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM This SWMP identifies the minimum elements to develop, implement and enforce a program to address stormwater runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that are located within the City of Trinity and discharge into the MS4. These elements are designed to minimize water quality impacts utilizing a combination of structural Stormwater Control Measures (SCMs) and/or non-structural BMPs appropriate for the community and ensure adequate long-term operation and maintenance of SCMs. In accordance with 15A NCAC 02H .0153 and .1017, the City of Trinity implements the following State post-construction program requirements, which satisfy the NPDES Phase II MS4 post-construction site runoff control requirements as Qualifying Alternative Programs (QAPs) in the MS4 area(s) where they are implemented. Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program State QAP Name State Requirements Local Ordinance / Regulatory Mechanism Reference Water Supply Watershed (WS-III) 15A NCAC 2B .0620 - .0624 “The Universal Stormwater Management Program Ordinance” for the City of Trinity, NC Article 3: Sec-308 Universal Stormwater Management Program 15A NCAC 2H .1020 “The Universal Stormwater Management Program Ordinance” for the City of Trinity, NC 2 The City of Trinity has existing requirements other than Qualifying Alternative Program(s) for implementation of the NPDES Phase II MS4 post-construction program requirements. These existing requirements are codified in local ordinance(s), and implementation is further defined in guidance, manuals and/or standard operating procedure(s) as summarized in Table 19 below. DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 27 Table 19: Summary of Existing Post-Construction Program Elements Permit Requirements for Plan Review and Approval Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.2(a) Authority USWMPO Article 1: Sec-102 09/02/2011 3.6.3(a) & 15A NCAC 02H.0153(c) Federal, State & Local Projects USWMPO Article 2: Sec-204 09/02/2011 3.6.3(b) Plan Review USWMPO Article 2: Sec-202 09/02/2011 3.6.3(c) O&M Agreement USWMPO Article 4: Sec-402 09/02/2011 3.6.3(d) O&M Plan USWMPO Article 4: Sec-403 09/02/2011 3.6.3(e) Deed Restrictions/Covenants USWMPO Article 4: Sec-405(A) 09/02/2011 3.6.3(f) Access Easements USWMPO Article 4: Sec-408 09/02/2011 Permit Requirements for Inspections and Enforcement Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.2(b) Documentation USWMPO Article 4: Sec-401, Sec-406 09/02/2011 3.6.2(c) Right of Entry USWMPO Article 5: Sec-503(B) 09/02/2011 3.6.4(a) Pre-CO Inspections USWMPO Article 2: Sec-203(D) 09/02/2011 3.6.4(b) Compliance with Plans USWMPO Article 4: Sec-401, Article 5: Sec-501 09/02/2011 3.6.4(c) Annual SCM Inspections USWMPO Article 4: Sec-403 09/02/2011 3.6.4(d) Low Density Inspections Permit Year 2 3.6.4(e) Qualified Professional USWMPO Article 3: Sec-305 09/02/2011 Permit Requirements for Fecal Coliform Reduction Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.6(a) Pet Waste USWMPO Article 3: Sec-308(1)(b) 09/02/2011 3.6.6(b) On-Site Domestic Wastewater Treatment City of Trinity Subdivision Ordinance Article VII: Section 7-4(E) 08/14/2017 City of Trinity Flood Damage Prevention Ordinance Article 5: Section A(10) 01/02/2008 USWMPO = Universal Stormwater Management Program Ordinance for the City of Trinity, NC The annual reporting metrics for the post construction program are provided in Table 20: Post Construction Site Runoff Control BMPs below. DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 28 Table 20: Post Construction Site Runoff Control BMPs Permit Ref. 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post-Construction Reporting Requirements Measures to document activities over the course of the fiscal year (July 1 – June 30) including appropriate information to accurately describe progress, status, and results. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 26. Standard Reporting Implement standardized tracking, documentation, inspections and reporting mechanisms to compile appropriate data for the annual self- assessment process. Data shall be provided for each Post-Construction/ Qualifying Alternative Program being implemented as listed in Tables 18 and 19. 1. Track number of low density and high density plan reviews performed 1. Continuously, permit years 1-5 1. Number of plan reviews performed for low density and high density 2. Track number of low density and high density plans approved 2. Continuously, permit years 1-5 2. Number of plan approvals issued for low density and high density 3. Maintain a current inventory of low density projects and constructed SCMs including SCM type or low density acreage, location and last inspection date 3. Continuously, permit years 1-5 3. Summary of number and type of SCMs added to the inventory; and number and acreage of low density projects constructed 4. Track number of SCM inspections performed 4. Continuously, permit years 1-5 4. Number of SCM inspections 5. Track number of low density inspections performed 5. Continuously, permit years 1-5 5. Number of low density projects inspected 6. Track number and type of enforcement actions taken 6. Continuously, permit years 1-5 6. Number of enforcement actions issued Permit Ref. 2.3 and 3.6: Qualifying Alternative Program(s) Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state program requirements. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric The QAP requirements are fully met by the existing QAP for post-construction, see references provided in Table 18 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 29 Table 20: Post Construction Site Runoff Control BMPs Permit Ref. 3.6.2: Legal Authority Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review designs and proposals for new development and redevelopment to determine whether adequate stormwater control measures will be installed, implemented, and maintained, (b) request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post-Construction Stormwater Management Program, and (c) enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater discharges to determine whether there is compliance with the Post-Construction Stormwater Management Program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric This permit requirement is fully met by the existing post-construction program, see references provided in Table 19 Permit Ref. 3.6.3: Plan Review and Approval Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal, State, and local government projects to comply with Post-Construction Program requirements throughout the entire MS4 permitted area, unless the entity is subject to its own NPDES MS4 permit or a qualifying alternative program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that complies with 15A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A NCAC 02H 1050 (9) and (10). BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric This permit requirement is fully met by the existing post-construction program, see references provided in Table 19 Permit Ref. 3.6.4: Inspections and Enforcement Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post- construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy. Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s), (b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require that inspections be conducted by a qualified professional. DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 30 Table 20: Post Construction Site Runoff Control BMPs BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 27. Revisions to Code of Ordinances Revise existing ordinance to specifically require inspection of low- density projects 1. Revise code to require inspection of low-density projects at least once during the permit term by a qualified professional 1. Permit year 2 1. Report code reference and date adopted Permit Ref. 3.6.6: Fecal Coliform Reduction Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H .1017(7). At a minimum, the program shall include: (a) A pet waste management component, which may be achieved by revising an existing litter ordinance, and (b) An on-site domestic wastewater treatment system component, if applicable, which may be coordinated with local county health department, to ensure proper operation and maintenance of such systems. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric This permit requirement is fully met by the existing post-construction program, see references provided in Table 19 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 31 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City of Trinity municipal facilities and operations. Pollution prevention and good housekeeping (PPGH) is accomplished through the implementation of seven required programs, which collectively address the ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and open space maintenance, fleet and building maintenance, new construction and land disturbances, and municipal storm sewer system maintenance. Pollution prevention and good housekeeping for municipal operations includes the following programs: 1. Municipal Facilities Operation and Maintenance Program 2. Spill Response Program 3. MS4 Operation and Maintenance Program 4. Municipal SCM Operation and Maintenance Program 5. Pesticide, Herbicide and Fertilizer Management Program 6. Vehicle and Equipment Maintenance Program 7. Pavement Management Program The City of Trinity will manage, implement and report the pollution prevention and good housekeeping BMPs as specified in Table 21 below for each required program. Table 21: Pollution Prevention and Good Housekeeping BMPs Permit Ref. 3.7.1: Municipal Facilities Operation and Maintenance Program Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities; perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on general stormwater awareness and implementing pollution prevention and good housekeeping practices. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 28. Municipal Facilities Operation and Maintenance Program Plan Continue to implement the existing written plan and evaluate annually 1. Maintain the written plan 1. Continuously 1. Yes/No/Status 2. Evaluate annually with Stormwater staff 2. Annually, in conjunction with annual self-assessment for permit years 1-4 2. Report any proposed changes 29. Staff Training Develop or identify a staff training program for general stormwater pollution prevention/spill 1. Identify or develop staff training program for municipal employees 1. Permit year 1 1. Yes/No/Status DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 32 Table 21: Pollution Prevention and Good Housekeeping BMPs response/fertilizer training/pavement management and overview of the PPGH plans and provide to appropriate utilities and public works employees 2. Train staff with PPGH responsibilities, street sweeping responsibilities, and staff that work at municipal equipment 2. Annually, permit years 1 - 5 2. Report number trained Permit Ref. 3.7.2: Spill Response Program Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response procedures. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 30. Spill Response Procedures Develop and maintain a list of city facilities and operations storing materials that would be a pollutant if spilled and introduced to the stormwater system and classify by hazard and quantity. Develop spill response procedures for these facilities 1. Train staff at facilities with potential for high hazard spills in first response actions and reporting procedures 1. See BMP No. 29 1. See BMP No. 29 2. Evaluate procedures annually with Stormwater staff 2. Annually, in conjunction with annual self-assessment for permit years 1-4 2. Report any proposed changes Permit Ref. 3.7.3: MS4 Operation and Maintenance Program Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections, maintain the collection system including catch basins and conveyances; and establish specific frequencies, schedules, and standard documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 31. MS4 System Inspections and Maintenance Plan Develop a proactive plan for MS4 system maintenance, requiring regular inspections and maintenance 1. Develop a SOP that includes proactive inspection schedules, standard documentation, staff responsibilities, and proper maintenance training 1. Permit year 2 1. Yes/No/Status 2. Perform MS4 inspections and maintenance 2. Perform in accordance with schedule adopted in the plan 2. Report the number of inspections performed and the number of issues remedied DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 33 Table 21: Pollution Prevention and Good Housekeeping BMPs Permit Ref. 3.7.4: Municipal SCM Operation and Maintenance Program Measures to manage municipally-owned, operated, and/or maintained structural stormwater control measures (SCMs) that are installed for compliance with the permittee’s post-construction program. The permittee shall maintain a current inventory of SCMs, perform SCM inspections and maintenance, and shall establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 32. Pollution Prevention and Good Housekeeping (PPGH) Plan Continue to implement the existing written plan and evaluate annually 1. Maintain the written plan 1. Continuously 1. Yes/No/Status 2. Evaluate annually with Stormwater staff 2. Annually, in conjunction with annual self-assessment for permit years 1-4 2. Report any proposed changes Permit Ref. 3.7.5: Pesticide, Herbicide and Fertilizer Management Program Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine pollution prevention and chemical use, storage and handling training, and shall ensure compliance with permits and applicator certifications. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 33. Applicator Training Continue training of City staff who apply landscape chemicals and are required to attend certification classes 1. Require staff to maintain certifications and verify 1. Annually, permit years 1-5 1. Report number of staff certified 34. Staff Training Develop or identify a staff training program for general stormwater pollution prevention/spill response/fertilizer training and overview of the PPGH plan and provide to public services department employees (see BMP No. 29) 1. See BMP No. 29 1. See BMP No. 29 1. See BMP No. 29 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 34 Table 21: Pollution Prevention and Good Housekeeping BMPs Permit Ref. 3.7.6: Vehicle and Equipment Maintenance Program Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 35. NPDES Industrial Permit Compliance Ensure that NPDES industrial permit compliance occurs at all applicable municipally owned sites 1. Review municipal facilities inventory to determine which facilities require a NPDES permit 1. Permit year 1 1. Number of facilities determined to require a NPDES Industrial Permit 2. Permitting of municipally owned facilities; apply for new permits and confirm that all existing permits are valid. Renew permits as required 2. Permit year 1, following review of facilities, and continuously thereafter 2. Report number of new permits received or renewed as well as number of active permits. 3. Establish NPDES Industrial Permit tracking mechanism to document list of municipally owned facilities with permit, permit expiration dates, and inspections 3. See BMP No. 3 3. See BMP No. 3 36. Vehicle and Equipment Cleaning and Maintenance Facility Inspection Routine inspections as part of general facility inspections (see BMP No. 28) to ensure that vehicle and equipment facilities are following proper procedures to minimize water quality impacts from vehicle and equipment cleaning and maintenance 1. See BMP No. 28 1. See BMP No. 28 1. See BMP No. 28 37. Vehicle and Equipment Cleaning and Maintenance Facility Staff Training Develop or identify a staff training program for general stormwater pollution prevention/spill response/fertilizer training and overview of the PPGH plan and provide to public services department employees (see BMP No. 29) 1. See BMP No. 29 1. See BMP No. 29 1. See BMP No. 29 DRAFT DRAFT NCS000502 SWMP City of Trinity July 30, 2021 Page 35 Table 21: Pollution Prevention and Good Housekeeping BMPs Permit Ref. 3.7.7: Pavement Management Program Measures to reduce pollutants in stormwater runoff from municipally-owned streets, roads, and parking lots within the permittee’s corporate limits. The permittee shall implement measures to control litter, leaves, debris, particulate and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 38. Street Sweeping Develop a plan to perform street sweeping following a regular schedule in order to reduce pollutants from City owned and maintained streets. 1. Develop an SOP, including a schedule and plan to document 1. Permit year 1 1. Yes/no/status 2. Implement SOP and documentation 2. Annually, beginning in permit year 2 2. Total number of street miles swept 39. Leaf Collection Develop a plan to perform periodic collection of leaves from residential and public areas to reduce pollutants and clogging of storm system inlets. 1. Develop an SOP, including a schedule and plan to document 1. Permit year 1 1. Yes/no/status 2. Implement SOP and documentation 2. Regularly, beginning in permit year 2 2. Volume of leaves collected (tons) 40. Vehicle Spill Cleanup An organized vehicle spill cleanup response to prevent pollutants from vehicular accidents from entering the storm drain system. 1. Maintain spill response procedures (See BMP No. 30) 1. See BMP No. 30 1. See BMP No. 30 2. Provide public education about stopping vehicle leaks (See BMP No. 6) 2. See BMP No. 6 2. See BMP No. 6 DRAFT