HomeMy WebLinkAboutNCS000545_Creedmoor Preliminary Draft SWMP_20210916
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C ity of Creed m oor, North
Carolina
Comprehensive Stormwater
Management Plan Update
In Support of the City’s
NPDES Phase II MS4 Permit
No. NCS000545
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Table of Contents
1 INTRODUCTION .......................................................................................................... 5
2 BACKGROUND INFORMATION ............................................................................... 7
2.1 Population Served ................................................................................................... 7
2.2 Growth Rate ............................................................................................................ 7
2.3 Ju risdic tiona l & M S4 Serv ice A reas ............................................................... 7
2.4 MS4 Conveyance System ....................................................................................... 8
2.5 Land Use Composition Estimates ........................................................................... 9
2.6 Estimation Methodology ..................................................................................... 10
2.7 TMDL Identification........................................................................................... 10
3 RECEIVING STREAMS ............................................................................................. 11
4 EXISTING WATER QUALITY PROGRAMS ........................................................... 12
4.1 Local Programs ..................................................................................................... 12
4.2 State Programs....................................................................................................... 12
5 PERMITTING INFORMATION.................................................................................. 12
5.1 Organizational Chart ............................................................................................. 12
5.2 Responsible Party Contact Person......................................................................... 13
5.3 Signing Official ..................................................................................................... 13
5.4 Duly Authorized Representative ....................................................................... 13
6 STORMWATER MANAGEMENT PROGRAM ........................................................ 13
6.1 Public Education & Outreach on Storm Water Impacts ....................................... 13
6.1.1 Target Pollutants and Stressors ...................................................................... 14
6.1.2 Target Audiences ........................................................................................... 14
6.1.3 Public Outreach and Education Program Implementation............................. 14
6.1.4 Program Assessment ...................................................................................... 16
6.2 Public Involvement & Participation ...................................................................... 19
6.2.1 Public Meeting ............................................................................................... 19
6.2.2 Public Involvement Program Implementation ............................................... 19
6.2.3 Program Assessment ...................................................................................... 21
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6.3 Illicit Discharge Detection & Elimination ............................................................ 23
6.3.1 IDDE Ordinance ............................................................................................ 24
6.3.2 Stormwater System Map ................................................................................ 24
6.3.3 Illicit Discharge Detection and Elimination Program .................................... 25
6.3.4 Employee Training......................................................................................... 26
6.3.5 Public Education and Outreach ...................................................................... 26
6.3.6 Program Assessment ...................................................................................... 26
6.4 Construction Site Stormwater/Runoff Control ...................................................... 29
6.5 Post Construction Stormwater Management- New Development and
Redevelopment ................................................................................................................. 31
6.5.1 Post Construction Legal Authority ................................................................ 31
6.5.2 Stormwater Control Measures ....................................................................... 32
6.5.3 Stormwater Permit Plan Review .................................................................... 32
6.5.4 SCM Operation and Maintenance Program ................................................... 33
6.5.5 Program Assessment ...................................................................................... 33
6.6 Pollution Prevention/Good Housekeeping for Municipal Operations .................. 36
6.6.1 Inventory of Municipal Facilities and Operations ......................................... 36
6.6.2 Operations and Maintenance Program at Municipal Facilities ...................... 37
6.6.3 Street Sweeping Operations ........................................................................... 38
6.6.4 Municipal Owned Stormwater Control Measures and MS4 System ............. 38
6.6.5 Employee Staff Training ................................................................................ 39
6.6.6 Vehicle and Equipment Cleaning Operations ................................................ 39
6.6.7 Program Assessment ...................................................................................... 40
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Acronym List
Abbreviation Definition
AICP American Institute of Certified Planners
BMP Best Management Practice
CAMA Coastal Area Management Act
CFR Code of Federal Regulations
CWEP Clean Water Education Partnership
CZO Certified Zoning Official
DEMLR Division of Energy, Mineral, and Land Resources
EMC Environmental Management Commission
EPA Environmental Protection Agency
ETJ Extra Territorial Jurisdiction
GIS Geographic Information System
IDDE Illicit Discharge Detection and Elimination
I&M Inspection & Maintenance
LID Low Impact Development
MS4 Municipal Separate Storm Sewer System
NCAC North Carolina Administrative Code
NCDEQ North Carolina Department of Environmental Quality
NOV Notice of Violation
NPDES National Pollutant Discharge Elimination System
NSW Nutrient Sensitive Water
SCM Stormwater Control Measure
SL Session Law
SNAP Stormwater Nitrogen and Phosphorus Tool
SWMP Stormwater Management Plan
SWPPP Stormwater Pollution Prevention Plan
TMDL Total Maximum Daily Load
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1 INTRODUCTION
On February 1, 2018, the City of Creedmoor (City) received their second National
Pollutant Discharge Elimination System (NPDES) permit (Permit No. NCS000545) from
the State of North Carolina Department of Environmental Quality (NCDEQ), Division of
Energy, Mineral, and Land Resources (DEMLR), authorizing them to discharge stormwater
from the City’s municipal separate storm sewer system (MS4) located within the City’s
corporate limits, to receiving waters of the State including Holman Creek, Beaverdam
Creek, Cedar Creek, Robertson Creek and Ledge Creek within the Neuse River Basin.
These discharges must be in accordance with the discharge limitations, monitoring
requirements, and other permit conditions including the development of this Stormwater
Management Plan (SWMP). This permit and plan are effective until February 1, 2023.
This SWMP is required by Part I, paragraphs A and G of the City’s NPDES MS4 permit.
The objective of the SWMP is to establish how the permit requirements are implemented to
achieve permit compliance. The SWMP plan details the program elements to be
implemented under the permit program and includes: the specific best management
practices (BMPs) that are intended to fulfill the permit requirements; frequency of each
BMP; measurable program goals; implementation schedules; and responsible positions.
The City’s Department of Community Development is the primary agency responsible for
managing the City’s NPDES MS4 permit, the MS4 system and the SWMP.
Implementation of the requirements within the permit and SWMP activities are coordinated
with the Department of Public Works and other applicable City departments as necessary.
Funding for the BMPs specified in the SWMP is provided by local stormwater utility fees,
except where noted.
The SWMP includes the following core NPDES MS4 permit programs:
1. Public Education and Outreach Program – This program provides the general public and
businesses with information on general water quality, pollution prevention, and reporting
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problems, as well as specialized information on various activities that have the potential to
cause pollution and harm water quality. This information is delivered through a wide range
of methods including print, web, radio, social media, presentations, and public events.
2. Public Involvement and Participation Program – This program provides the general
public and businesses the opportunity to participate in various programs within the City’s
SWMP. Litter cleanup events and the Pharmeceutical Drug Disposal Program are available
as public volunteer opportunities.
3. Illicit Discharge Detection and Elimination Program – This program is designed to
protect water quality by detecting and eliminating pollution sources such as improper
sewage or wastewater connections, illegal discharges of hazardous materials, other
chemicals and litter. As part of this program, the City enforces the “City of Creedmoor
Watershed Protection Ordinance,” (Ord. 2018-O-09, ZTA-2018-05) which defines illicit
discharges and provides enforcement measures if illicit discharges are discovered. The City
is mapping its MS4 system to inspect for and track illicit discharges more efficiently. The
City relies on regular inspections of the MS4 system and reports from the public to assist in
identifying and eliminating these sources of pollution.
4. Construction Site Stormwater Runoff Control Program – This program is designed to
control sediments and other pollutants from construction sites. The NCDEQ Division of
Land Resources Erosion and Sediment Control Program effectively meets the
requirements of the Construction S ite Runoff Controls in the City of Creedmoor by
permitting and controlling development activities disturbing one or more acres of
land surface and those activities less than one acre that are part of a larger common plan
of development.
5. Post-Construction Stormwater Management Program – This program is designed to
control the discharge of pollutants in stormwater runoff from new development and
applicable redevelopment projects. As part of this program, the City enforces the “City of
Creedmoor Watershed Protection Ordinance,” which requires structural stormwater
controls for new development and applicable redevelopment projects as defined by current
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State law. The program involves review and approval of project plans as well as site
inspections and maintenance activities to ensure that treatment practices are properly
operated and maintained.
6. Pollution Prevention/Good Housekeeping Program – This program focuses on ensuring
that City facilities and field operations are managed in a way that minimizes stormwater
pollutant discharges. Stormwater Pollution Prevention Plans and Spill Response Plans are
maintained for applicable facilities that conduct activities with the potential for stormwater
pollutant discharges. The City conducts inspections and training sessions at these facilities
to ensure that requirements are being met. Good housekeeping measures such as street
sweeping and off-site car washing have been implemented to reduce pollution.
2 BACKGROUND INFORMATION
2.1 Population Served
The City serves a current population of approximately 4,800 people. This is the
population based on information from the 2020 census. This data is located at
https://www2.census.gov/programs-surveys/decennial/2020/data/01-Redistricting_File--
PL_94-171/. Previous years of population data were found on the North Carolina Office of
State Budget and Management website
(https://files.nc.gov/ncosbm/demog/muniestbymuni_2019.html). This population does not
have seasonal variability.
2.2 Growth Rate
The following table (Table 1) provides historic estimated population data for the City from
the North Carolina Office of State Budget and Management website. According to this
information, the population growth during the 9-year time period shown was 14%, or 1.5%
per year (compounding).
YEAR POPULATION
2020 4,866
2019 4,703
2010 4,124
Table 1. Population Data for the City of Creedmoor
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2.3 Ju risdic tiona l & M S 4 Serv ice A reas
Figure 1 shows City’s official map, which includes the City’s jurisdictional boundary
as well as the City’s Extraterritorial Jurisdictional (ETJ) Areas. The size of these
area’s as well as the size of the Land Area served by the MS4 are described in further
detail below. The MS4 area is the City’s jurisdictional boundary (corporate limits).
Figure 1. Official City Map for the City of Creedmoor
1. Lan d Ar ea of Primar y Corporate Lim its 5.32 square m iles
2. Land Ar ea o f Secondary (Satellite) Corporate
Limits
0.12 square m iles
3. Estimated L and Area serv ed by M S4 5.44 square miles
2.4 MS4 Conveyance System
The City’s MS4 Conveyance system is currently being mapped by The Wooten
Company with an estimated completion date of December 2021. This system is
comprised of stormwater drains, concrete structures, culvert pipes, grass swales, and
associated outfalls. The system also has several privately-owned stormwater control
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measures (SCM) and one SCM owned and operated by the City, at the Creedmoor
Community Center, built for the purposes of post-construction stormwater
management, which were constructed to meet requirements of the NPDES permit and
this SWMP. Upon completion of the map, this report will be updated to include a
copy.
Figure 2. SAMPLE - City of Creedmoor is in Phase 3 of a 3 year mapping process with
The Wooten Company. The above map shows the progress made towards stormwater
mapping. Maps will be in addition to an atlas that The Wooten Company is working on.
2.5 Land Use Composition Estimates
Figure 2 is a zoning map of the City, which shows the various land uses within the City.
The estimated size of these areas is provided in the further detail below.
1. Residential Land Use: 3.18 square miles 30.78%
2. Commercial Land Use: 0.68 square miles 6.56%
3. Industrial Land Use: 0.33 square miles 3.16%
4. Open Space: 6.14 square miles 59.50%
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Figure 2. Zoning Map for the City of Creedmoor
2.6 Estimation Methodology
GIS mapping information was used to determine the area and ratio of land uses. Simple
land area calculations were completed using the following logic:
Residential Areas: Areas currently zoned for Residential Use
Commercial Areas: Areas currently zoned for Commercial Use
Industrial Areas: Areas currently zoned for Industrial Use
Open Space: Areas currently zoned for Open Space
MS4 Service Area: Area of the City’s Corporate Limits
2.7 TMDL Identification
The City is currently not subject to any TMDL nutrient reduction requirements. However,
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the City does provide nitrogen and phosphorus reduction as part of the Falls Lake Nutrient
Management Strategy (SL 2005-190; Falls Lake Rules; S981) The goal of these strategies
is to reduce concentrations of chlorophyll-a concentrations in the Lake.
3 RECEIVING STR EA MS
Stormwater from the City is discharged to following designated waters of the State (as
shown on Figure 3):
• Holman Creek
• Beaverdam Creek
• Cedar Creek
• Robertson Creek
• Ledge Creek
• Whitaker Branch
Figure 3. City of Creedmoor Designated Waters of the State
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4 EXISTING WATER QUALITY PROGRAMS
4.1 Local Programs
Local Nutrient Sensitive Waters Strategy: YES
Local Water Supply Watershed Program: YES
Delegated Erosion and Sediment Control Program: NO
CAMA Land Use Plan: NO
4.2 State Programs
Erosion and Sediment Control Program: YES
5 PERMITTING INFORMATION
5.1 Organizational Chart
Figure 4 below is the most current Organizational Chart for City departments and
staff that are involved the stormwater program implementation.
Figure 4. City of Creedmoor Stormwater Organization Chart
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5.2 Responsible Party Contact Person
Contact: Michael Frangos, AICP, CZO Title: Stormwater Administrator Street Address: 111 Masonic Street PO Box: PO Box 765 City: Creedmoor State: North Carolina Zip Code: 27522 Telephone: (919) 764-1016 Fax Number: (919) 528-3052 E-mail Address: mfrangos@cityofcreedmoor.org
5.3 Signing Official
Contact: Michael Frangos, AICP, CZO Title: Stormwater Administrator Street Address: 111 Masonic Street PO Box: PO Box 765 City: Creedmoor State: North Carolina Zip Code: 27522 Telephone: (919) 764-1016 Fax Number: (919) 528-3052 E-mail Address: mfrangos@cityofcreedmoor.org
5.4 Duly Authorized Representative
Under Article 19, Section 2, Subsection 19.14-1 of the Creedmoor Development Ordinance
(Appendix A), the City Board of Commissioners shall designate a Stormwater
Administrator. Michael Frangos, AICP, CZO, Community Development Director was duly
appointed as the Stormwater Administrator for the City on November 20th, 2018, by the
City Board of Commissioners. This plan will be updated upon any changes to this
appointment.
6 STORMWATER MANAGEMENT PROGRAM
6.1 Public Education & Outreach on Storm Water Impacts
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the City will implement a
public education program to distribute educational materials to the community or conduct
equivalent outreach activities about the impacts of storm water discharges on water bodies
and the steps that the public can take to reduce pollutants in storm water runoff.
The following sub-sections explain:
• Target audience and pollution sources;
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• Program implementation; and
• Program assessment
6.1.1 Target Pollutants and Stressors
The City has defined the target pollutants and stressors that it will address as part of
its Public Education and Outreach Program as Nitrogen and Phosphorus. These
nutrients in stormwater contribute to the exceedance of chlorophyll-a in the Falls
Lake Watershed. Non-point sources of these pollutants include yard maintenance
and debris, fertilizers and animal waste.
6.1.2 Target Audiences
The City has identified all residents within the City limits, pet owners, and school
children as the target audience of their Public Education and Outreach Program.
City residents were selected because they are most likely to apply fertilizer on their
property, often without the knowledge or training necessary to apply fertilizers
properly. Without this knowledge or training, excessive amounts of Nitrogen and
Phosphorus can enter the MS4 system. Pet owners were selected because animal
waste can also be a contributor of Nitrogen and Phosphorus if not disposed of
properly. School Children were selected because educating them about stormwater
practices instills a sense of responsibility and environmental stewardship which
they can bring home to encourage positive behavior in their families.
6.1.3 Public Outreach and Education Program Implementation
The City’s Stormwater Public Education and Outreach Program will provide water
quality and pollution prevention messages to educate residents about the ways they
can help protect water quality and get involved to help reduce stormwater pollution.
The program will provide these messages through the following ways:
1. An internet web site. The City’s Stormwater Website
(https://www.cityofcreedmoor.org/departments-and-
services/community-development/planning-zoning/stormwater-
program/what-you -can-do) will contain information regarding
the City’s NPDES permit, the stormwater hotline /helpline(as
described in detail below) and links to public education materials
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(as described in detail below) and to additional information at the
Clean Water Education Partnership (CWEP).
2. Public education materials. A wide variety of print media and
promotional materials about water quality and pollution
prevention will be maintained and provided to the public. This
includes brochures and fact sheets. Print media and promotional
products will be distributed during public events, presentations,
and/or through direct mail.
3. Public outreach events. The City’s Community Development
Office has previously presented a stormwater education booth at
the annual Public Works Day event and City of Creedmoor
Music Festival, distributed public education materials as
described above, displayed a slide show regarding stormwater,
and conducted demonstrations regarding impacts to stormwater
from erosion. The City will continue to conduct public outreach
events, these events may stay the same or change based upon the
results of the annual program evaluation.
4. Mass media and social media. The City will continue to utilize
several media sources to educate the public regarding
stormwater. The City will maintain a contract with CWEP to
produce and distribute an environmental education media
campaign on local television stations. The City will publish one
or more educational articles per year in the City’s newsletter,
Creedmoor Happenings. The City will post one or more articles
per year on their Facebook page.
5. A stormwater hotline/helpline. The City will continue to
maintain a stormwater hotline/helpline and advertise it on the
City’s stormwater website. The City will also advertise the
hotline/helpline on stormwater informational posters which will
be displayed throughout the City. The City will maintain a
tracker to track complaints and outcomes. Calls to any City
office regarding stormwater will be routed to the Community
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Development office, and Community Development employees
will provide stormwater education to citizens during the course
of these calls.
6. School Presentations. The City will continue to maintain a
contract with CWEP to conduct an annual stormwater education
lesson at South Granville High School.
7. Pet Waste Cleanup Stations. The City has installed several pet
waste cleanup stations on City owned properties and along the
Cross City Trail to educate the public of the importance of
cleaning up pet waste in maintaining a healthy environment and
waterways. The City will continue to maintain their pet waste
stations.
6.1.4 Program Assessment
The overall success of the Public Education and Outreach Program is evaluated
through the successful implementation of the components of the program and
reported with each NPDES MS4 annual report. This plan will be updated should the
evaluation find that some measures have not met measurable goals. Additional
information regarding program assessment can be found in Table 2 below.
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Table 2: Public Outreach and Education BMPs.
BMP Measurable Goals Schedule for Implementation Reporting Metric
a. Establish Goals and
Objectives
Define the goals and objectives of the Public
Education and Outreach program based upon
community wide issues
Throughout the permit period, with
annual evaluation and updates if
necessary
Goals and objectives will be evaluated
annually and updated as needed
b. Describe target pollutants
Identify the target pollutant and target pollutant
sources the
permittee’s public education program is designed to
address and why
they are an issue.
Throughout the permit period, with
annual evaluation and updates if
necessary
Targeted pollutants will be evaluated
annually and updated as needed.
c. Describe targeted
audiences
Identify the target audiences likely to have
significant stormwater
impacts and why they were selected.
Throughout the permit period, with
annual evaluation and updates if
necessary
Target audiences will be evaluated
annually and updated as needed.
d. Describe residential and
industrial/commercial issues
Identify and describe residential and
industrial/commercial water quality issues such as
pollutants, sources of pollutants, and impacts on
water quality.
Throughout the permit period, with
annual evaluation and updates if
necessary
Residential and industrial/commercial
issues will be evaluated annually and
updated as needed.
e. Informational Website Promote and maintain Internet web site.
Throughout the permit period, with
annual evaluation and updates if
necessary
The number of unique and total page visits
will be recorded annually
f. Distribute Public Education
materials to target audiences
Develop stormwater educational material to
appropriate target groups as likely to have a
significant stormwater impact.
Throughout the permit period, with
annual evaluation and updates if
necessary
The number of educational materials that
were distributed to target audiences will
be recorded annually
g. Maintain hotline/helpline
Maintain and promote a stormwater hotline/helpline
for the purpose of public education and outreach
Throughout the permit period, with
annual evaluation and updates if
necessary
Number of calls to hotline/helpline to
report water quality issues will be
recorded annually. Number of
mechanisms utilized to share
hotline/helpline (e.g., brochures,
promotional items) will be recorded
annually
h. Implement a Public
Education and Outreach
Program
Establish and implement a public education and
outreach program through a combination of
approaches designed to reach the target audiences.
Throughout the permit period, with
annual evaluation and updates if
necessary
Extent of exposure will be recorded
annually for each outreach and education
strategy
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For each media, event or activity estimate and record
the extent of exposure.
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6.2 Public Involvement & Participation
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the City will implement a
public involvement and participation program which must, at a minimum, comply with
State and local public notice requirements.
The following sub-sections explain:
• The public meeting;
• Program implementation; and
• Program assessment.
6.2.1 Public Meeting
The City held several Board of Commissioners meetings during the first permit
term, which are open to public citizens, regarding their stormwater program on May
22, 2012 (discussion regarding potential stormwater utility rates), June 26, 2013
(discussion regarding the Stormwater Utility Ordinance and Stormwater Program
for New Development), July 24, 2012 (discussion regarding Interlocal Agreement
for Stormwater), and August 28, 2012 (discussion regarding Stormwater Plan
Review). The City will bring any update to this plan to the Planning Board and
Board of Commissioners for Board approval and public comment.
6.2.2 Public Involvement Program Implementation
The City’s Stormwater Public Involvement Program provides residents
opportunities to protect water quality and get involved to help reduce stormwater
pollution. The program provides these opportunities through the following ways:
1. Volunteer Opportunities. The City will provide volunteers the
opportunity to help educate their community about stormwater
pollution through several events.
a. Litter Sweep. The City collaborates with local
volunteer groups such as Boy Scouts and local
business to clean up litter from local waterways and
parks. The City also has annual litter cleanups along
roadways in conjunction with the North Carolina
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Department of Transportation’s statewide cleanup.
Local citizens are invited to participate in these
events, which are advertised on the City website.
b. Operation Medicine Drop. The City hosts a twice-
annual collection of unused or expired prescription or
over-the-counter medications to keep them out of
landfills and from polluting local waterways. A
Pharmaceutical drug disposal box is also located in
City Hall for year round anonymous disposal of
prescription medication.
2. An internet website. The City’s will continue to maintain a “What
You Can Do” page and link to a brochure educating citizens on what
they can do to protect stormwater on their website.
(https://www.cityofcreedmoor.org/departments-and-
services/community-development/planning-zoning/stormwater-
program/what-you -can-do)
3. Community Outreach. The City will continue to collaborate with the
community during the development of City land conservation
projects including conservation easements, greenway trails, other
connections to open space in the City. These projects are supported
by the Clean Water Management Trust Fund, the Triangle Land
Conservancy, the North American Land Trust, and the Upper Neuse
Clean Water Initiative.
4. A stormwater hotline/helpline. The City will continue to maintain a
stormwater hotline/helpline which is advertised on the City’s
stormwater website. The City will also advertise the hotline/helpline
on stormwater informational posters which will be displayed
throughout the City. The City will maintain a tracker to track
complaints and outcomes. Calls to any City office regarding
stormwater will be routed to the Community Development office,
and Community Development employees will provide stormwater
education to citizens during the course of these calls.
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6.2.3 Program Assessment
The overall success of the Public Involvement and Participation Program is
evaluated through the successful implementation of the components of the program
and reported with each NPDES MS4 annual report. Additional information
regarding program assessment can be found in Table 3 below.
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Table 3: Public Involvement and Participation BMPs
BMP Measurable Goals Schedule for Implementation Reporting Metric
a. Allow the public an opportunity to review
and comment on the Stormwater Program
Conduct at least one public meeting during
the permit period to allow the public an
opportunity to review and comment on the
Stormwater Program.
One public meeting will be held during this
permit period
Meeting minutes and attendees from the
public meeting will be recorded
b. Establish and implement a volunteer
community involvement program
Organize and promote volunteer
opportunities to promote ongoing citizen
participation in the stormwater program
Evaluation of the program will be conducted
annually with updates to the program if
necessary.
The number of events and number of
volunteers will be recorded annually
c. Mechanism for Public Involvement
Establish a mechanism for public
involvement
One public meeting will be held during this
permit period. Evaluation of the program
will be conducted annually with updates to
the program if necessary.
Meeting minutes and attendees from the
public meeting will be recorded. The
mechanism for public involvement will be
evaluated annually and updated as needed.
d. Maintain hotline/helpline
Maintain and promote a stormwater
hotline/helpline for the purpose of public
involvement
Evaluation of the program will be conducted
annually with updates to the program if
necessary.
Number of calls to helpline/hotline to report
water quality issues will be recorded
annually.
Number of mechanisms utilized to share
hotline/helpline (e.g., brochures, promotional
items) will be recorded annually
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6.3 Illicit Discharge Detection & Elimination
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the City must:
a) Develop, implement and enforce a program to detect and eliminate illicit
discharges (as defined at Sec. 122.26 (b)(2)) into our MS4;
b) Develop a storm sewer system map, showing the location of all outfalls and the
names and location of all waters of the United States that receive discharges
from those outfalls;
c) Effectively prohibit, through ordinance, or other regulatory mechanism, non-
storm water discharges into our storm sewer system and implement appropriate
enforcement procedures and actions;
d) Develop and implement a plan to detect and address non-storm water discharges
and illegal dumping into our system;
e) Inform public employees, businesses, and the general public of hazards
associated with illegal discharges and improper disposal of waste; and
f) Address the following categories of non-storm water discharges or flows (i.e.,
illicit discharges) if we identify them as significant contributors of pollutants
into our MS4:
1) water line flushing,
2) landscape irrigation (including lawn watering & irrigation water)
3) diverted stream flows,
4) rising ground waters,
5) uncontaminated ground water infiltration (as defined at 40 CFR
35.2005(20)),
6) uncontaminated pumped ground water,
7) discharges from potable water sources,
8) foundation drains,
9) air conditioning condensation,
10) springs,
11) water from crawl space pumps,
12) footing drains,
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13) individual residential car washing,
14) flows from riparian habitats and wetlands,
15) de-chlorinated swimming pool discharges, and
16) street wash water
17) Exceptions include: discharges or flows from fire-fighting activities
(excluded from the effective prohibition against non-storm water and
will only be addressed where they are identified as significant sources
of pollutants to waters of the United States).
The following sub-sections explain:
• The BMPs intended to meet program requirements;
• Integral components of the IDDE program;
• Education strategy; and
• Program Assessment.
6.3.1 IDDE Ordinance
The City adopted its Watershed Protection Ordinance (Article 19) on June 18, 2012
and subsequently amended the Ordinance on November 20, 2018 per Ord. 2018-O-
09, ZTA-2018-05. Section 6 of this ordinance specifically addresses Illicit
Discharges. This ordinance is enforced as part of the NPDES MS4 permit and
SWMP. Detailed administration, remediation and enforcement procedures are
maintained for the ordinance.
6.3.2 Stormwater System Map
The City has contracted with The Wooten Company to produce a map of the City’s
MS4 stormwater system. The City will maintain and update the inventory of its
MS4 system using Geographic Information Systems (GIS) which includes data for
major outfalls and sub-basins. New stormwater infrastructure will be entered into
the GIS inventory for new development projects. Inventory data will be stored and
maintained digitally. Hard copy maps showing major outfalls and receiving
streams can be produced as needed. This report will be updated with a copy of the
map once it has been completed
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6.3.3 Illicit Discharge Detection and Elimination Program
The City will continue to implement their IDDE program in the following ways:
1. Outfall Inspections/Inventory – Monitoring of dry weather flows
will be conducted by the City’s Public Works and Community
Development staff during routine maintenance and inspection
site visits. If dry weather flows are observed; sensory cues are
used and samples are collected to determine if the flow is a
pollution source. Immediate follow-up field screening activities
are initiated to identify and eliminate pollution sources. Notice of
Violation (NOVs) are sent to the property owner if illicit
discharges are discovered during the inspection process. The City
has created a stormwater inspection tracker to track all
stormwater outfall inspections, outcomes and resolutions (if any).
The City has also created an IDDE tracker to track any IDDE
NOVs and resolutions.
2. Water Quality Monitoring – Water quality monitoring will be
conducted to identify illicit connections and discharges,
determine general water quality conditions and target water
quality problem areas for additional follow-up actions. Water
quality monitoring reports will be produced annually to
document findings of the sampling.
3. A stormwater hotline/helpline. The City will continue to
maintain a stormwater hotline/helpline which is advertised on the
City’s stormwater website. The City will also advertise the
hotline/helpline on stormwater informational posters which will
be displayed throughout the City. The City has developed a
tracker to track complaints and outcomes. Calls to any City
office regarding stormwater will be routed to the Community
Development office, and Community Development employees
[26]
will provide stormwater education to citizens during the course
of these calls.
6.3.4 Employee Training
Training about illicit discharges will continue to be provided to a variety of City
employees, including Public Works and Stormwater Administration staff, and
typically includes:
• How to recognize common illicit discharges;
• Their impact on surface water quality;
• Why protecting surface water is important for the community;
• Pollution prevention practices;
• How to report illicit discharges; and
• How these reports are investigated and enforced.
The City will continue to update information on employee training including names
of courses, dates, and certifications.
6.3.5 Public Education and Outreach
The City will continue to maintain a public education and outreach program to
inform businesses and the general public about illicit discharges and improper waste
disposal and how they impact the environment. This education and outreach
program includes instructions regarding the proper method for reporting illicit
discharges on the City’s website. Public education and outreach items for the IDDE
Program are included as a component of the Public Education and Outreach
Program described in Section 6.1 above.
6.3.6 Program Assessment
The overall success of the IDDE Program is evaluated through the successful
implementation of the components of the program and reported with each NPDES
MS4 annual report. Additional information regarding program assessment can be
found in Table 4 below.
[27]
Table 4: Illicit Discharge and Detection Elimination BMPs
BMP Measurable Goals Schedule for Implementation Reporting Metric
a. Maintain an Illicit Discharge Detection
and Elimination Program
Develop and implement an Illicit Discharge
Detection and Elimination Program
including provisions for program assessment
and evaluation.
The program has been implemented. The
program will be maintained throughout the
permit period, with annual evaluation and
updates if necessary.
The IDDE program will be evaluated
annually and updated as needed
b. Maintain appropriate legal authorities
Maintain adequate ordinances or other legal
authorities to prohibit illicit discharges and
enforce the approved Illicit Discharge
Detection and Elimination Program.
The ordinance has been approved and
implemented. Annual evaluation and updates
will be made throughout the permit period if
needed.
The effectiveness of the ordinance will be
evaluated annually and updated as needed
c. Develop and maintain a Storm Sewer
System Map of Major Outfalls
Map identifying major outfalls and
stormwater drainage system components. At
a minimum, components include major
outfalls and receiving streams. Establish
procedures to continue to identify, locate,
and update the map of the drainage system.
The Storm Sewer System map is currently
being produced with ongoing updates being
made as needed.
The system map will be evaluated annually
and updated as needed
d. Inspection/detection, tracking and
elimination program to detect illicit
discharges including dry weather flows
Establish written procedures for detecting
and tracing the sources of illicit discharges
and for removing the sources or reporting the
sources to the State to be properly permitted.
Establish and implement tracking of
investigations.
The program has been implemented. The
program will be maintained throughout the
permit period, with annual evaluation and
updates if necessary.
Observed discharges, results of investigation,
follow up, and case closure dates will be
reported annually
[28]
e. Provide employee training
Implement training program for appropriate
municipal staff, who, as part of their normal
job responsibilities, may come into contact
with or otherwise observe an illicit discharge
or illicit connection to the storm sewer
system. The training program shall identify
appropriate staff, the schedule for conducting
the training and the proper procedures for
reporting and responding to an illicit
discharge or connection. Follow-up training
shall be provided as needed to address
changes in procedures, techniques, or
staffing.
Employee training will be conducted
throughout the permit period, with annual
evaluation and updates to the training
program if necessary.
Document and maintain records of the
training provided and the staff trained.
f. Provide public education
Inform public employees, businesses, and
general public of hazards associated with
illegal discharges and improper disposal of
waste.
Public education will be conducted
throughout the permit period, with annual
evaluation and updates to the education
program if necessary
Public Education materials will be evaluated
annually and updated as needed
g. Provide a public reporting mechanism
Promote, publicize, and facilitate a reporting
mechanism for the public and staff to report
illicit discharges and establish and
implement citizen request response
procedures. Conduct reactive inspections in
response to complaints and follow-up
inspections as needed to ensure that
corrective measures have been implemented
by the responsible party to achieve and
maintain compliance.
A public reporting hotline has been
implemented. The hotline will remain the
permit period, with annual evaluation and
updates if necessary
Number of calls to hotline to report illicit
discharges will be recorded annually
Reports to the hotline and outcomes from
those calls will be reported annually
h. Provide a mechanism to enforce the IDDE
ordinance
The permittee shall implement a mechanism
to track the issuance of notices of violation
and enforcement actions. This mechanism
shall include the ability to identify chronic
violators for initiation of actions to reduce
noncompliance.
The mechanism to enforce the IDDE
program has been implemented via
ordinance. Enforcement will continue
throughout the permit period, with annual
evaluation and updates if necessary
NOVs and enforcement actions will be
reported annually
[29]
6.4 Construction Site Stormwater/Runoff Control
Pursuant to Federal Regulations 40 CFR Section 122.34(b) the City must develop,
implement, and enforce a program to reduce pollutants in any storm water runoff into our
MS4 from construction activities that result in a land disturbance of greater than or equal to
one acre. Reduction of storm water discharges from construction activity disturbing less
than one acre will be included in our program if that construction activity is part of a larger
common plan of development or sale that would disturb one acre or more. If the NPDES
permitting authority waives requirements for storm water discharges associated with small
construction activity in accordance with Sec. 122.26(b)(15)(i), we are not required to
develop, implement, and/or enforce a program to reduce pollutant discharges from such
sites. The program will include the development and implementation of, at a minimum:
a) An ordinance or other regulatory mechanism to require erosion and sediment
controls, as well as sanctions to ensure compliance, to the extent allowable
under State, Tribal, or local law;
b) Requirements for construction site operators to implement appropriate erosion
and sediment control best management practices;
c) Requirements for 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 impacts to water quality;
d) Procedures for receipt and consideration of information submitted by the public,
and
e) Procedures for site inspection and enforcement of control measures.
Pursuant to 40 CFR 122.35, an operator of a regulated small MS4 may share the
responsibility to implement the minimum control measures with other entities
provided:
a) The other entity, in fact, implements the control measure;
[30]
b) The particular control measure, or component thereof, is at least as stringent
as the corresponding NPDES permit requirement; and
c) The other entity agrees to implement the control measure on behalf of the
MS4.
Pursuant to State Requirements in Session Law 2006-246 Section 7 "to obtain a
Phase II National Pollutant Discharge Elimination System (NPDES) permit for storm-
water management, [the city] shall, to the extent authorized by law, develop,
implement, and enforce a stormwater management plan approved by the Commission
that satisfies the six minimum control measures required by Code 40 of Federal
Regulations §122.34(b)(1 July 2003 Edition)." Regulated entities may propose using any
existing State or local program that relates to the minimum measures to meet, either in
whole or in part, the requirements of the minimum measures.
The NCDEQ Division of Land Resources Erosion and Sediment Control
Program effectively meets the requirements of the Construction S ite Runoff Controls
in the City of Creedmoor by permitting and controlling development activities
disturbing one or more acres of land surface and those activities less than one acre that
are part of a larger common plan of development. This program is authorized under
the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North
Carolina Administrative Code. This program includes procedures for public input,
sanctions to ensure compliance, requirements for construction site operators to
implement appropriate erosion and sediment control practices, review of site plans
which incorporates consideration of potential water quality impacts, and procedures
for site inspection and enforcement of control measures. The NCG0 10000 permit
establishes requirements for 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 impacts to water quality.
[31]
6.5 Post Construction Stormwater Management- New Development
and Redevelopment
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the City must
develop, implement, and enforce a program to address storm water 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 discharge into our MS4. The program will ensure that
controls are in place that would prevent or minimize water quality impacts. The City
will at a minimum:
a) Develop and implement strategies which include a combination of structural
and/or non-structural best management practices (BMPs) appropriate for
our community;
b) U se an o rd in an ce or o th er regulatory m echa ni sm to a ddress po st-
constru ctio n run off fr o m n ew dev elopm ent an d red eve lopm en t projects to
the ex tent allo w able un d er State, Tr ib a l or local la w ; an d
c) E nsur e ad equ ate long-t erm o pera tio n an d m ain tena nc e of B M P s.
The following sub-sections explain:
• The BMPs intended to meet program requirements;
• Integral components of the program; and
• Program Assessment.
6.5.1 Post Construction Legal Authority
The City has adopted several mechanisms to meet the legal requirements o f the
Post-C onstru ction S to rm w ater M an agem en t P ro g ra m including the Post-
constru ctio n Storm w ater R unoff C ontro ls fo r D ev elopm en t in th e Fall s
W atersh ed . The storm w ater m anagem e nt and w ater q ua lit y p ro tection
promulgated in R u le 15A NCAC 0 2B .0 277 S torm w a ter M an agem en t fo r N e w
D ev elo pm ent, an d R ule 15A N C A C 02B .0278 S to rm w a ter M an agem en t fo r
E x istin g D ev elopm ent effectively m eets the P ost-con stru c tio n Sto rm w ate r
R un off contro l requirem en ts w ith in th e Fall s Lak e W ater Supply .
[32]
6.5.2 Stormwater Control Measures
BMP strategies for the City’s Post-Construction Stormwater Management program
will consist mainly of structural stormwater control measures (SCMs) such as sand
filters, wet ponds, wetlands, and bioretention areas. SCMs should be designed in
accordance with the NC Department of Environmental Quality Stormwater
Design Manual (NCDEQ BMP Manual). SCMs will be required on projects that
have high density development and disturb more than one-half acre of land for
residential or recreational development that is not part of a larger common plan of
developer or sale or disturb more than 12,000 square feet of land for non-
residential/recreational developments that are not part of a larger common plan of
development or sale. In addition, SCMs must be designed to:
• Reduce Nitrogen and Phosphorus loads to not exceed 2.2 and 0.33 pounds per acre
per year, respectively;
Control and treat the runoff generated from all surfaces by one inch of rainfall;
• Control the peak flow from the 1-year – 24-hour storm event; and
• Convey the runoff from the 10-year storm event without surcharging the drainage
system.
The program will also require proper operation, maintenance, and inspection of
SCMs as discussed in Section 6.5.4 below.
6.5.3 Stormwater Permit Plan Review
For a stormwater permit to be reviewed and issued by the City of Creedmoor,
several documents must be submitted. The documentation required to apply for a
stormwater permit consists of:
• City Stormwater Permit Application;
• SNAP Tool (an interactive Excel spreadsheet that calculates nutrient reduction);
• Three (3) sets of plans;
• A copy of the operations and maintenance manual for the engineered SCM’s
proposed;
• Application fee (as listed in the City's Fee and Rate Schedule)
[33]
All permit requirements will continue to be provided to developers on the City
webpage (https://www.cityofcreedmoor.org/departments-and-services/community-
development/planning-zoning/stormwater-program/obtaining-stormwater-permits).
6.5.4 SCM Operation and Maintenance Program
The City will continue to require deed restrictions and protective covenants to
ensure that SCMs remain consistent with approved plans. Streams and buffer
boundaries will be required on all surveys and record plats. An operation and
maintenance agreement for SCMs will be required to be referenced on record plats
and recorded in deeds. In addition, a maintenance easement will be required to be
recorded to provide access to structural SCMs.
The City will also require an operation and maintenance agreement executed by the
responsible party (owner) of each SCM. As part of the program, the owner will be
required to:
• Conduct annual inspections of SCMs;
• Submit inspection reports to the City;
• Repair any deficiencies in the SCM found during the inspection process;
• Obtain and submit performance and maintenance security or bonds for each SCM
annually; and
• Maintain proper records documenting operation and maintenance activities.
Any owner that fails to submit the required documents and properly maintain their
SCM may be subject to an enforcement action by the City. The City will continue
to maintain electronic copies of all SCM plans, inspection reports, securities/ bonds
and enforcement actions.
6.5.5 Program Assessment
The overall success of the Post-Construction Stormwater Management Program is
evaluated through the successful implementation of the components of the program
and reported with each NPDES MS4 annual report. Additional information
regarding program assessment can be found in Table 5 below.
[34]
Table 5: Post-Construction Stormwater Management Program BMPs
BMP Measurable Goals Schedule for Implementation Reporting Metric
a. Establish a Post-Construction Stormwater
Management Program, including legal
authorities
Develop and adopt by ordinance (or similar
regulatory mechanism) a program to address
stormwater runoff from new development
and redevelopment. Implement and enforce
the program within 24 months of the permit
issue date. Annually review and
revise/update as necessary
The City's Watershed Development
ordinance has been developed, approved and
implemented. Evaluation annually.
The effectiveness of the ordinance will be
evaluated annually and updated as needed.
b. Establish strategies which include BMPs
appropriate for the MS4
Develop strategies that include a
combination of structural and/or
nonstructural BMPs. Provide a mechanism to
require long-term operation and maintenance
of structural BMPs. Require annual
inspection reports of permitted structural
BMPs performed by a qualified professional
(i.e., someone trained and certified by NC
State for BMP Inspection & Maintenance).
The stormwater management and water
quality protection promulgated in Rule 15A
NCAC 02B .0277 Stormwater Management
for New Development, and Rule 15A NCAC
02B .0278 Stormwater Management for
Existing Development effectively meets the
Post-Construction Stormwater Runoff
control requirements within the Falls Lake
Water Supply.
The effectiveness of the Falls Rules will be
evaluated annually and updates to the City's
program made as needed
c. Plan reviews
Conduct site plan reviews of all new
development and redeveloped sites that
disturb greater than or equal to one acre and
discharge to the MS4 (including sites that
disturb less than one acre that are part of a
larger common plan of development or sale).
Plan reviews will be conducted throughout
the permit period.
The effectiveness of the plan reviews will be
evaluated annually and updated as needed.
The number of plans reviewed and approved
will be tracked annually.
d. Inventory of projects with post-
construction structural stormwater control
measures
Maintain an inventory of projects with post-
construction structural stormwater control
measures installed and implemented at new
development and redeveloped sites,
including both public and private sector sites
located within the permittee’s jurisdiction
area that are covered by its postconstruction
ordinance requirements.
Inventory has been completed, is updated
continuously and evaluated annually.
Number of new SCMs associated with a
project that have received a Certificate of
Occupancy.
[35]
BMP Measurable Goals Schedule for Implementation Reporting Metric
e. Deed restrictions and protective covenants
Provide mechanisms such as deed
restrictions or protective covenants to ensure
development activities will remain consistent
with approved plans
Mechanism is complete. Evaluate and
update annually as needed. Continuously
ensure that deed restrictions and protective
covenants are recorded.
New deed restrictions or protective
covenants are recorded annually.
f. Long-term Operation and Maintenance of
structural SCMs
Require an operation and maintenance plan
for the long-term operation SCMs.
O&M requirements have been put in place
through the City's Watershed Protection
ordinance. Evaluate and update annually as
needed.
Ensure that O&M plans are required and
recorded throughout the permit term.
Evaluation conducted annually.
Ensure that annual inspections are performed
by a qualified professional. Evaluation
conducted annually.
Track annual inspection reports, security
bonds, and any operation and maintenance
activities.
g. Inspections
Conduct and document inspections of each
project site covered under performance
standards, at least one time during the permit
term.
Inspections will be conducted throughout the
permit term. The inspection program will be
evaluated annually.
Track annual inspections and maintain
inspection records.
h. Educational materials and training for
developers
Make available through paper or electronic
means, ordinances, post-construction
requirements, design standards checklists,
and other materials appropriate for
developers.
Educational materials for developers can be
found on the City's website. Evaluation of
these materials will be conducted annually.
Education materials will be evaluated
annually and updated as needed
i. Enforcement
Track the issuance of notices of violation and
enforcement actions. This mechanism shall
include the ability to identify chronic
violators for initiation of actions to reduce
noncompliance.
This tracking mechanism has been
implemented and will be evaluated annually.
Number of NOVs and other enforcement
actions reported annually. The effectiveness
of the enforcement mechanism will be
evaluated annually.
[36]
6.6 Pollution Prevention/Good Housekeeping for Municipal
Operations
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the city will
develop and im plement an operation and m aintenance pro gram that includes a training
component and has the ultimate goal of preventing or reducing pollutant run off from
municipal opera tions. U sing training m aterials that are available from EPA, the State of
North Carolina, or other organizations, our pro gram w ill include em ploye e tra ining to
prevent and reduce stormw ater pollution from activities such as park and open space
maintenan ce, fleet and building m aintenance, new construction and land disturban ces,
and storm water system maintenan ce.
The following sub-sections explain:
• The BMPs intended to meet program requirements;
• Integral components of the program;
• Employee education and training; and
• Program assessment.
6.6.1 Inventory of Municipal Facilities and Operations
The City provides an extensive network of municipal operations designed to serve
its citizens and keep vital infrastructure functioning properly. All parcels of land
owned or operated by the City are examined to determine whether they are included
in the Municipal Facilities Inventory within the Pollution Prevention/Good
Housekeeping Program. A Standard Administrative Procedure is followed when
evaluating parcels for this inventory. Once included in the inventory, facilities will
receive:
• Preparation and implementation of a Stormwater Pollution Prevention Plans
(SWPPP);
[37]
• Regular inspections; and
• Annual employee training.
At the time of this report, only the operations the City’s Public Works Facility is
thought to have potential impact to the City’s MS4 system. To reduce any potential
impact, the City will maintain operation and maintenance programs and spill
prevention plans at the Public Works Facility and any other facilities that are
identified later. The City will continue to implement best management practices
(described in Section 6.6.2 and 6.6.3 below) to minimize negative impacts to the
storm drain system. This is accomplished through a process of:
• Observing and inspecting field operations;
• Updating best management practices and SOPs; and
• Training employees.
6.6.2 Inspection and Maintenance Program at Municipal Facilities
The inspection and maintenance program at the City’s Public Works Facility
includes:
• Thorough assessment of facility operations and maintenance activities;
• Evaluation of waste disposal and storage methods;
• Evaluation of the stormwater drainage system, including catch basin inlets,
structural best management practices and outfalls;
• Review of spill response and clean up procedures with recommended revisions as
appropriate;
• Evaluation of housekeeping practices with recommended revisions as necessary to
eliminate potential pollution sources;
• Evaluation of outdoor storage areas and recommendations for elimination of
potential pollution sources;
• Identification and elimination of dry weather discharges;
• Review and update (if needed) of the SWPPP; and
• Completion of a written report documenting findings and recommendations.
[38]
Follow-up inspections, communication and meetings with appropriate personnel
will be conducted as necessary to eliminate potential pollution sources. Facility
personnel, typically a supervisor and/or management personnel, will participate in
inspections and will be responsible for implementation of SWPPPs and best
management practices.
6.6.3 Street Sweeping Operations
Streets can be a significant source of stormwater pollution, particularly leaves,
which can contribute nitrogen and phosphorus (the City’s target pollutants) to local
waterways. In order to address this source, the City will continue to conduct street
sweeping operations. The City will continue to contract with American Road
Conservation to provide quarterly vacuum truck sweeping for all residential areas
where curb and gutter are present. The City will continue to maintain
documentation regarding each sweeping event including miles swept and pounds of
debris collected. The City is in the process of developing an evaluation program for
its street sweeping operation, with the goal of determining the amount of nitrogen
and phosphorus removed from their roadways on an annual basis. This information
will be utilized to determine if street sweeping operations should be adjusted for
future permit years.
6.6.4 Municipal Owned Stormwater Control Measures and MS4
System
The City currently has one municipally owned SCM, located at the Creedmoor
Community Center. This SCM is inspected several times per year. Maintenance is
conducted as needed based on inspection results. Standard inspection forms are
used to conduct and document inspections with this information maintained in a
database.
The City’s Public Works staff will continue to conduct cleaning and maintenance of
the MS4 system. Services will include, but will not limited to:
[39]
• Catch basin cleaning (manually and with jet trucks);
• Catch basin top cleaning (manually and with jet trucks);
• Stormwater pipe cleaning (by jet truck); and
• Repairs if needed.
Crews will also respond to service requests for cleaning of the MS4 system. All
work will be recorded and maintained in a spreadsheet.
6.6.5 Employee Staff Training
Training will continue to be conducted for employees at the Public Works facility.
The goal of training is to inform employees of the actions necessary to reduce the
discharge of pollutants from their facilities/operations and protect water quality.
Some of the topics that will included in the training are:
• Description of common pollutants, their sources and water quality impacts;
• Description of the actions they should take to reduce discharges of pollutants, with
an emphasis on good housekeeping;
• Description of effective spill response and prevention measures that should be
employed at each facility;
• Discussion of typical pollution sources at municipal operations and specific
actions that should be taken to eliminate these sources and protect water quality;
• Review of the SWPPP where applicable;
• Explanation of the potential negative consequences of failing to control pollutants
at facilities; and
• Overview of IDDE Program and how to report observed water quality problems.
6.6.6 Vehicle and Equipment Cleaning Operations
The City recognizes the negative impacts that vehicle and equipment wash water
runoff can have on stormwater and, ultimately, surface waters. To reduce those
[40]
impacts, the City has contracted with AutoBrite Car Washes, Inc. (AutoBrite) to
wash all Police Department, Public Works and Community Development vehicles
and most larger pieces of vehicle equipment. AutoBrite car washes are self-service
car washes with a discharge capture system.
6.6.7 Program Assessment
The overall success of the Pollution Prevention and Good Housekeeping Program is
evaluated through the successful implementation of the components of the program
and reported with each NPDES MS4 annual report. Additional information
regarding program assessment can be found in Table 6 below.
[41]
Table 6: Pollution Prevention and Good Housekeeping BMPs
BMP Measurable Goals Schedule for Implementation Reporting Metric
a. Inventory of municipally owned or
operated facilities
Maintain, evaluate annually, and update as
necessary an inventory of facilities and
operations owned and operated by the
permittee with the potential for generating
polluted stormwater runoff.
The inventory of municipally owned and
operated facilities has been completed and is
updated annually.
Inventory reviewed annually and updated as
necessary.
b. Inspection and Maintenance (I&M) for
municipally owned or operated facilities
Maintain and implement, evaluate annually
and update as necessary an I&M program for
municipally owned and operated facilities
with the potential for generating polluted
stormwater runoff. The I&M program shall
specify the frequency of inspections and
routine maintenance requirements.
The program has been implemented and
maintained and will continue to be evaluated
annually throughout the permit term.
Inspections will be documented annually for
each facility.
Document number of completed inspections
and maintenance actions. The effectiveness
of the I&M program will be evaluated
annually and updated as needed.
c. Spill Response Procedures for municipally
owned or operated facilities
Maintain written spill response procedures
for municipal operations.
Spill response procedures will be evaluated
annually.
Document if spill response procedures have
been completed for each facility. Spill
response reviewed annually and updated as
necessary.
d. Streets, roads, and public parking lots
maintenance
Maintain and implement a program to reduce
polluted stormwater runoff from
municipally-owned streets, roads, and public
parking lots.
Street sweeping of roads and streets is
conducted quarterly on all roadways with
curb and gutter.
Provide documentation of sweeping events,
miles swept and characterize the quantity and
composition of the trash and debris.
e. I&M program for municipally owned
catch basins and conveyance systems
Maintain and implement an I&M program
for the stormwater sewer system including
catch basins and conveyance systems that it
owns and maintains
Implementation of program in place –
evaluate annually and update as needed.
Document and report any inspection issues,
when maintenance is performed and how
many inlets on each street are inspected.
Records to include date of inspection,
inspector, and linear footage of
inspections/maintenance.
f. Identify structural stormwater controls
Maintain a current inventory of municipally-
owned or operated structural stormwater
controls installed for compliance with the
City's Watershed Protection Ordinance.
Inventory and mapping of SCMs at all
facilities within MS4 service area has been
completed. Inventory will be reviewed
annually and updated as needed.
Inventory reviewed annually and updated as
necessary.
[42]
BMP Measurable Goals Schedule for Implementation Reporting Metric
g. I&M program for municipally owned or
maintained structural stormwater controls
Maintain and implement, assess annually and
update as necessary an I&M program for
municipally owned or maintained structural
stormwater controls.
Document inspections and maintenance of
all municipally-owned or maintained
structural stormwater controls.
I&M program for municipal SCMs has been
implemented. Document inspections and
maintenance required annually for each
facility.
Document and report number of inspections
and maintenance actions needed. Document
and report maintenance actions performed.
h. Pesticide, Herbicide and Fertilizer
Application Management.
Ensure municipal employees and contractors
are properly trained and all permits,
certifications, and other measures for
applicators are followed.
The training program has been implemented
and will be conducted annually.
Document number of staff members with
active certification.
i. Staff Training
Implement an employee training program for
employees involved in implementing
pollution prevention and good housekeeping
practices.
Training program has been implemented.
Training is documented annually.
Document and report who is trained, number
of staff trained, training dates, and topics
covered.
j. Prevent or minimize contamination of
stormwater runoff from all areas used for
vehicle and equipment cleaning.
Implement a program to minimize
contamination of stormwater runoff by
vehicle and equipment cleaning.
The City has contracted with AutoBrite Car
Washes, Inc. to provide vehicle washing that
minimizes contamination of stormwater
Provide documentation regarding contracted
vehicle washing services