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Home My WebLink About02_NCS000559_Draft-SWMP-2022_20220512Draft Stormwater Management Plan MS4 Town of Clayton, NC NCS000559 January 1, 2022 [Add MS4 logo and/or photos as desired] Table of Contents PART 1: INTRODUCTION PART 2: CERTIFICATION 1 2 PART 3: MS4 INFORMATION............................................................................................................. 3 3.1 Permitted MS4 Area................................................................................................................. 3 3.2 Existing MS4 Mapping............................................................................................................4 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.................................................................................................10 4.3 Shared Responsibility.............................................................................................................11 4.4 Co-Permittees........................................................................................................................11 4.5 Measurable Goals for Program Administration....................................................................... I I PART 5: PUBLIC EDUCATION AND OUTREACH PROG 14 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM.........................................17 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM ............................18 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM.................................................21 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ...................................... 23 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS.....................28 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 PART 1: INTRODUCTION The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the Town of Clayton 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 Town of Clayton 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 NCS000559, as issued by NCDEQ. This permit covers activities associated with the discharge of stormwater from the MS4 as owned and operated by the Town of Clayton and located within the corporate limits and ETJ of the Town of Clayton. In preparing this SWMP, the Town of Clayton has evaluated its MS4 and the permit requirements to develop a comprehensive 5-year SWMP that will meet the community's needs, address local water quality issues, and provide the minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated annually to ensure that the elements and minimum measures it contains continue to adequately provide for permit compliance and the community's needs. Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along with any approved modifications of the SWMP, are incorporated by reference into the permit and become enforceable parts of the permit. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 1 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. ❑ lam 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 NCS000559 SWMP Town of Clayton January 1, 2022 Page 2 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This SWMP applies throughout the corporate limits and the ETJ (extra -territorial jurisdiction) of the Town of Clayton, including all regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits and the ETJ of the Town of Clayton as of the date of this document. --N.... Miles �.' ` us DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 3 3.2 Existing MS4 Mapping The current MS4 mapping includes pipes, flow direction, drop inlets, catch basins, stormwater manholes, stormwater junction boxes, culverts, stormwater control measures (SCMs) and stormwater outfalls. Some of the mapped drainage features do include information such as type of material, pipe diameter, culvert dimensions, and inverts. The SCMs include the type and location, and when available, reference to the recorded Operation and Maintenance Manual. link to public MS4 GIS map: hops://townofclgytonnc.maps.arcgis.com/appsNiew/index.html?appid=bffb l 7l 3b0964814a646dff748c9 2elc Table 1: Summary of MS4 Mapping (as of 2021 annual report) Percent of MS4 Area Mapped 65 % No. of Major Outfalls* Mapped 193 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. 3.3 Receiving Waters The Town of Clayton MS4 is located within the Neuse 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 Table 2: Summary of MS4 Receiving Waters Receiving Water Name Stream Index / AU Number Water Quality Classification 303(d) Listed Parameter(s) of Interest Big Arm Creek 27-38-1 C; NSW n/a Little Creek 27-43-12 C; NSW Benthos (Nar, AL, FW) Marks Creek 27-38 C; NSW n/a Neuse River 27-(36) WS-V; NSW Copper (7u /l, AL, FW); Zinc (50u /l, AL, FW) Neuse River 27-(38.5) WS-IV; NSW n/a C — Class C (secondary recreation: fishing, boating, swimming) NSW — Nutrient Sensitive Waters WS-V — drain to WS-IV DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 4 WS-IV — sources of water supply for drinking Benthos (Nar, AL, FW) — narrative standard, aquatic life, fresh waters Copper (lug/l, AL, FW) — numeric level, aquatic life, fresh waters Zinc (50ug/l, AL, FW) — numeric level, aquatic life, fresh waters Data from NC Surface Water Classifications Map and 2020 Final 303(d) List. The 2020 303(d) Listing and Delisting Methodology identifies the Narrative criterion as the following: "Waters shall be suitable for aquatic life propagation and maintenance of biological integrity. NC uses benthic and fish community data to assess biological integrity. Biological integrity means the ability of an aquatic ecosystem to support and maintain a balanced and indigenous community of organisms having species composition, diversity, population densities and functional organization similar to that of reference conditions (15A NCAC 02B .0202)." Copper has an acute standard of 3.6 ug/l and a chronic standard of 2.7 ug/1 at 25 mg/l in -stream hardness. Zinc has a standard of 36 ug/l at 25 mg/l in -stream hardness. 3.4 MS4 Interconnection The Town of Clayton MS4 is not interconnected with another regulated MS4 and directly discharges to the receiving waters as listed in Table 2 above. 3.5 Total Maximum Daily Loads (TMDLs) The TMDL(s) listed in Table 3 below have been approved within the 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) Neuse River Total Nitrogen Y Y Statewide Mercury N N The TMDL for Total Nitrogen is a 30% reduction from the baseline load. NO reductions are required for Mercury at this time. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 5 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, as determined by a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Map as provided by the U.S. Fish and Wildlife Service. Of those species listed, Table 4 summarizes the species that may be significantly impacted by the quality of surface waters within their habitat. Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality Scientific Name Common name Species Group Federal Listing Status Elli do steinstansana Tar River spinymussel Clams Endangered Alasmidonta heterodon Dwarf wed emussel Clams Endangered Noturus furiosus Carolina madtom Fishes Endangered Elli do lanceolata Yellow lance Clams Threatened Fusconaia masom Atlantic pigtoe Clams Threatened Necturus lewisi Neuse River waterdog Amphibians Threatened 3.7 Industrial Facility Discharges The Town of Clayton MS4 jurisdictional area includes the following industrial facilities which hold NPDES Industrial Stormwater Permits, as determined from the NCDEQ Active NPDES Stormwater Permit List and/or Active Stormwater Permits Man. Table 5: NPDES Stormwater Permitted Industrial Facilities Permit Number Facility Name (owner) NCG030690 Clayton Machine Development Center (Caterpillar Inc.) NCG030211 Caterpillar Incorporated (same) NCG060402 Novo Nordisk-DAPI-US (Novo Nordisk Pharmaceuticals Industries LP) NCG060048 Novo Nordisk Pharmaceuticals Industries, LP (same) NCG060039 Grifols Therapeutics LLC (same) NCG200498 Renew Recycling LLC (same) NCG110080 Little Creek Water Reclamation (Town of Clayton) 3.8 Non-Stormwater Discharges The water quality impacts of non-Stormwater discharges have been evaluated by the Town of Clayton as summarized in Table 6 below. The unpermitted non-Stormwater flows listed as incidental do not significantly impact water quality. The Division has not required that other non-stormwater flows be specifically controlled by the Town of Clayton. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 6 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 crawls ace 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 *The Town of Clayton has evaluated residential and charity car 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, wash water associated with car washing that does contain detergents and discharges directly into the MS4 has been determined to have a possible impact to water quality. Therefore, public education and outreach will be utilized to mitigate this impact (see BMPs No. 4 and 5). **Street cleaning performed by the Town is accomplished with a wet street sweeper, therefore, runoff from street washing is relevant to the MS4. Discharges associated with such activities will be addressed under the Pavement Management Program in Part 10 of this SWMP. 3.9 Target Pollutants and Sources In addition to those target pollutants identified above, the Town of Clayton 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 Town of Clayton has evaluated schools, homeowners and businesses as target audiences that are likely to have significant stormwater impacts. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 7 Table 7: Summary of Target Pollutants and Sources Target Pollutant(s) Likely Source(s)/Target SWMP Program Addressing Target Audience(s) Pollutant(s)/Audience(s) Nitrogen New Stormwater Ordinance (Post Construction) Development/developers Sediment Construction site/contractors Erosion Control Ordinance (Construction Site Runoff Controls) Yard Waste Residents and Businesses Public Education and Outreach; Pollution Prevention and Good Housekeeping Litter Residents and Businesses Public Education and Outreach; Pollution Prevention and Good Housekeeping Household Residents Public Education and Outreach; Illicit Discharge Hazardous Waste Ordinance (IDDE) Fats, Oils, Greases Residents, Restaurants Public Education and Outreach; Illicit Discharge (FOG) Ordinance (IDDE); Pollution Prevention and Good Housekeeping Fecal Coliform Residents Public Education and Outreach; Illicit Discharge Ordinance (IDDE) Illicit Discharges Residents and Businesses Public Education and Outreach; Illicit Discharge Ordinance (IDDE); Pollution Prevention and Good Housekeeping Improper Disposal Residents and Businesses Public Education and Outreach; Illicit Discharge of Waste Ordinance (IDDE) Illegal dumping Residents and Businesses Public Education and Outreach DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 8 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure [Provide a brief narrative description of the organizational structure of the Town of Clayton as it relates to stormwater program implementation and permit compliance] The Town of Clayton stormwater program is implemented by several departments within the organization. The various departments include Engineering, Public Works, Water Resources, Parks and Recreation, Fire Department, and the Executive Team. [Insert an organization chart that shows responsible positions as listed in Table 8] Table 8: Summary of Responsible Parties SWMP Component Responsible Position Staff Name Department Stormwater Program Town Stormwater Susan Locklear Engineering Administration Engineer SWMP Management Town Stormwater Susan Locklear Engineering En ineer Public Education & Town Stormwater Susan Locklear Engineering Outreach Engineer Public Involvement & Town Stormwater Susan Locklear Engineering Participation Engineer Illicit Discharge Town Stormwater Susan Locklear Engineering Detection & Engineer Elimination Construction Site Town Stormwater Susan Locklear Engineering Runoff Control Engineer Post -Construction Town Stormwater Susan Locklear Engineering Stormwater Engineer Management Pollution Water Resources Byron Water Resources/Public Prevention/Good Director/Public Works Poelman/vacant/Dolores Works/Executive Team Housekeeping for Director/Property Gill Municipal Operations Maintenance Municipal Facilities Water Resources Byron Water Resources/Public Operation & Director/Public Works Poelman/vacant/Dolores Works/Executive Team Maintenance Program Director/Property Gill Maintenance DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 9 Spill Response Program Fire Chief Lee Barbee Fire Department MS4 Operation & Town Stormwater Susan Locklear Engineering Maintenance Program Engineer Municipal SCM Town Stormwater Susan Locklear Engineering Operation & Engineer Maintenance Program Pesticide, Herbicide & Parks and Recreation Scott Barnard Parks and Recreation Fertilizer Management Director Program Vehicle & Equipment Fleet Service Supervisor Joe Pitt Public Works Cleaning Program Pavement Management Street Maintenance Rusty Clawson Public Works Program Superintendent Total Maximum Daily Town Stormwater Susan Locklear Engineering Load (TMDL) Engineer Requirements 4.2 Program Funding and Budget In accordance with the issued permit, the Town of Clayton 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 Stormwater Program currently receives funding of approximately $ XXXXX per year; funded through the General Fund. The program has 1 full-time staff and I part-time staff for program implementation. The program is currently under -funded to conduct all the proactive elements of the permit. Further fiscal analysis and investigation of funding options will be conducted as indicated in BMP No. 3 in order to supplement the current funding allocation. [Insert a brief summary of the fiscal analysis and, if adequate funding is not currently provided, the gap analysis results for funding necessary to implement this SWMP and comply with the MS4 Permit. Do not attach the full fiscal analysis or gap analysis, the Division will specifically request these documents if they are needed]. [If the gap analysis indicates that additional funding is needed to implement the SWAP and comply with the MS4 Permit, then enter the primary steps that will be taken to fully fund the total annual stormwater program budget in Table 11: Program Administration BMPs]. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 10 4.3 Shared Responsibility The Town of Clayton 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 Town of Clayton remains responsible for compliance if the other entity fails to perform the permit obligation and may be subject to enforcement action if neither the Town of Clayton 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 Implementing Entity & Program Name Legal Agreement Permit Requirement (Y/N) Permit Section 3.2.2 and 3.2.4 Clean Water Education Partnership (CWEP) Y 4.4 Co-Permittees There are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000559 for the Town of Clayton. 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 4.5 Measurable Goals for Program Administration The Town of Clayton will manage and report the following Best Management Practices (BMPs) for the administration of the Stormwater Management Program. Table 11: Program Administration BMPs Permit Part 2, Section A: Program Implementation Ref. Measures to evaluate the performance and effectiveness of the SWMP program components at least annually. Results shall be used by the permittee to modify the program components as necessary to accomplish the intent of the Stormwater Program. The self -assessment reporting eriod is the fiscal year (Jul 1— June 30). BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 1. Annual Self -Assessment DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 11 Table 11: Program Administration BMPs Perform an annual evaluation of 1. Prepare, certify and 1. Annually for Permit 1. Annual Self- SWMP implementation, suitability of submit the Annual Self- Years 1 — 4 Assessment received by SWMP commitments and any Assessment to NCDEQ NCDEQ no later than proposed changes to the SWMP prior to August 31 each August 31 each year. utilizing the NCDEQ Annual Self- year. Assessment Template. Permit 1.6: Permit Renewal Application Ref. Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the NPDES MS4 permit. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 2. Permit Renewal Application Audit stormwater program 1. Participate in an 1. TBD — Typically 1. N/A implementation for compliance with NPDES MS4 Permit Permit Year 4 the permit and approved SWMP, and Compliance Audit, as utilize the results to prepare and scheduled and performed submit a permit renewal application by EPA or NCDEQ. 2. Self -audit and 2. Permit Year 5 2. Submit Self -Audit to package. document any DEMLR (required stormwater program component of permit components not audited renewal application by EPA or NCDEQ package). utilizing the DEQ Audit Template. 3. Certify and submit the 3. Permit Year 5 3. Permit renewal stormwater permit application package renewal application received by DEQ at least (NOI, Self -Audit, and 180 days prior to permit Draft SWMP for the next expiration. 5-year permit cycle). DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 12 Permit 2.A.1: Adequate Funding and Staffing Ref. Maintain adequate funding and staffing to implement and manage the provisions of the SWMP and meet all re uirements of MS4 permit. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 3. Adequate Funding Perform fiscal and staffing analysis 1. Complete fiscal and 1. Permit Year 1 1. Report monetary value and explore options to achieve staffing gap analysis of gap and staffing adequate program funding in order to needs/shortages meet all requirements of MS4 permit. 2. Identify potential 2. Permit Year 2 2. Report funding funding mechanisms mechanism 3. Implement funding 3. Permit Year 3 3. Implemented? mechanisms I I Yes/No/Status DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 13 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM The Town of Clayton 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 Town of Clayton 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) Nitrogen New Development/Developers Sediment Contractors Yard Waste General Public, Businesses Litter General Public, Businesses Household Hazardous Waste General Public Fats, Oils, Greases (FOG) General Public, Businesses, Municipal Employees Fecal Coliform General Public Illicit Discharges General Public, Businesses, Municipal Employees Improper Disposal of Waste General Public, Businesses, Municipal Employees Illegal Dumping General Public, Businesses, Municipal Employees The Town of Clayton will manage, implement, and report the following public education and outreach BMPs. Two existing Town events, Square to Square July 4"' Celebration and the Harvest Festival, will be used as a platform for stormwater outreach and education. The Town will also develop a stormwater web page and brochures. Educational signage will be installed at Town facilities with SCMs in public view. The Town is an active partner in CWEP (Clean Water Education Partnership) which helps to implement public educate and outreach to a larger regional audience. Table 13: Public Education and Outreach BMPs Permit 3.2.2 and 3.2.4: Outreach to Targeted Audiences Ref. Measures to identify the specific elements and implementation of a Public Education and Outreach Program to share educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The permittee shall provide educational information to identified target audiences on pollutants/sources identified in table 12 above, and shall document the extent of exposure of each media, event or activity, including those elements implemented locally or through a cooperative agreement. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 14 Table 13: Public Education and Outreach BMPs #4. Partnership with CWEP The Town will engage with CWEP to 1. Arrange partnership 1. Each Permit 1. Provide Legal Agreement develop Education and Outreach with CWEP and establish Year Initiatives that will be administered legal agreement. 2. Attend regularly 2. Quarterly 2. Provide schedule of by CWEP. Initiatives will focus on residential, commercial, and school scheduled CWEP meetings meetings attended audiences within the MS4 area. 3. Outreach initiatives 3. Annually 3. CWEP Annual Report #5. Town Sponsored Events/Festival The Town will distribute information 1. Develop stormwater 1. current 1. Is brochure available? on stormwater during at least one maintenance brochure to Yes/No/Status City sponsored event or festival a hand out at festivals year, such as Square to Square or 2. Coordinate event dates 2. Annually 2. Was CWEP staff available? Harvest Festival. with CWEP to have Yes/No/Status additional persons available to assist in the event 3. Document the number 3. Annually 3. Report the number of of individuals that visited individuals that visited tent. the stormwater tent during the event #6. SCM signage Educational signage will be added to 1. Locate City -owned 1. See BMP No. 1. See BMP No. XX Town -owned SCMs that are visible SCMs and add them to the XX to the public. -inventory 2. Develop educational 2. Permit Year 1 2. Report number of signs signage that identifies developed. SCM, describes it function and notes website 3. Install signs 3. Permit Year 2 3. Report number of signs installed. Permit 2.1.7, 3.2.3 and 3.6.5(c): Web Site Ref. 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 A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #7. Stormwater Page on Town website Web page will provide information 1. Establish stormwater 1. Permit year 1 1. Link to webpage on the Town's Stormwater Program. web page. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 15 Table 13: Public Education and Outreach BMPs Information will include applicable 2. Maintain webpage. 2. Annually 2. Has annual maintenance ordinances, MS4 permit, SWMP and Verify links are working; occurred for webpage? links to additional stormwater update information. Yes/No educational resources. Permit 3.2.5: Stormwater Hotline Ref. Measures for a Stormwater hotline/helpline for the purpose of public education and outreach. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #8. Stormwater Complaint Database A phone log will be maintained of 1. Establish phone number 1. Permit year 1-5 1. report number of citizen concerns and questions and responsible party concerns/complaints/questions regarding stormwater issues DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 16 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 Town of Clayton 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 A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #9. Stormwater Page on Town Website See BMP #7 1. See BMP #7 1. See BMP #7 1. See BMP #7 #10. Stormwater Complaint Database See BMP #8 1. See BMP #8 1. See BMP #8 1. See BMP #8 #11. Partnership with CWEP See BMP #4 1. See BMP #4 1. See BMP #4 1. See BMP #4 #12. Town Sponsored Events/Festival See BMP #5 1. See BMP #5 1. See BMP #5 1. See BMP #5 Permit Ref. 3.3.2: Volunteer Opportunities Measures to provide volunteer opportunities designed to promote ongoing citizen participation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #13. Catch Basin stenciling/stamping Coordinate events with local HOA and conservation groups to identify inlets for labeling. 1. Number of markers installed. 1. Year 1 1. How many markers have been installed? #14. Promote regional creek week CWEP has an annual creek week that the Town will advertise through social media. 1. Number of hits on social media 1. Year 3 1. How many hits on social media? DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 17 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The Town of Clayton will develop, manage, implement, document, report and enforce an Illicit Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs. Table 15: Illicit Discharge Detection and Elimination BMPs Permit 3.4.1: MS4 Map Ref. Measures to develop, update and maintain a municipal storm sewer system map including stormwater conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric #15. Verify major outfalls to MS4 map Review current mapping for 1. Major outfall layer 1. Annually 1. Number of major completeness. outfalls? 2. Flow directions 2. Annually 2. Percentage of map with flow directions 3. Receiving waters 3. Annually 3. Percentage of map with receiving waters identified #16. Update MS4 Map The MS4 map will be updated as as- 1. As new systems are 1. Annually 1. How many new built plans are received for additional located or constructed, outfalls were identified? development and as new systems are the map will be updated. discovered. #17. Complete MS4 Mapping The MS4 mapping will be completed 1. 100% mapping of 1. Year 3 1. Percentage of mapping by contracting services to outside MS4 in Town Limits and completed firm to assist Town who has limited ETJ resources. Permit 3.4.2: Regulatory Mechanism Ref. Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4, includin enforcement procedures and actions. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric #18. Maintain Legal Authority Review existing ordinance; update if 1. Review ordinance 1. Annually 1. Ordinance adoption required to maintain legal authority to date. Is update required? prohibit, detect, and eliminate illicit connections or discharges, illegal dumping ands ills into MS4. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 18 Table 15: Illicit Discharge Detection and Elimination BMPs Permit 3.4.3: IDDE Plan Ref. Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4. The plan shall provide standard procedures and documentation to: a) Locate priority areas likely to have illicit discharges, b) Conduct routine dry weather outfall inspections, c) Identify illicit discharges and trace sources, d) Eliminate the source(s) of an illicit discharge, and e) Evaluate and assess the IDDE Program. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric #19. Develop IDDE Standard Procedures Develop internal procedures for 1. Standard Operation 1. Year 1 1. Are SOPS IDDE investigations Procedures documented documented? Yes/No #20. Outfall Inspections Perform regular dry weather (no rain 1. Train field staff to 1. Annually 1. Number of dry in previous 72 hours) outfall perform dry weather weather inspections inspections to proactively identify outfall inspections performed? illicit discharges and connections. Permit 3.4.4: IDDE Tracking Ref. Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was observed, the results of the investigation, any follow-up of the investigation, the date the investigation was closed, the issuance of enforcement actions, and the ability to identify chronic violators. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric #21. Record Keeping Establish filing system that enables 1. Track number of illicit 1. Annually 1. How many reports of Town staff to report the number of discharge investigations illicit discharge were illicit discharge "investigations" investigated? performed. Permit 3.4.5: Staff IDDE Training Ref. Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities, may observe an illicit discharge, illicit connection, illegal dumping or spills. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping and spills. Each staff training event shall be documented, including the a ends/materials, date, and number of staff participating. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 19 Table 15: Illicit Discharge Detection and Elimination BMPs #22. Staff Training Develop program to educate Town 1. Identify Town staff to 1. Year 1 1. How many Town staff staff of indicators of potential illicit be trained are identified to be discharges/connections and illegal trained? 2. Schedule staff training 2. Annually 2. How many Town staff dumping and the appropriate means of reporting such incidents. sessions were trained? #23. Fact Sheets Hang fact sheet posters in staff 1. Purchase/Develop 1. Year 3 1. Yes/No/Status common areas for educational educational posters purposes and reminders of basics of 2. Display education 2. Year 3 2. Number of identifying and reporting illicit posters in common areas posters/common areas discharges/connections. Permit 3.4.6: IDDE Reporting Ref. Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained ersonnel. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #24. Stormwater Engineer The Stormwater Engineer is trained 1. Number of illicit 1. Annually 1. How many illicit to assist in educating public in illicit discharge/connections discharges reported? discharges and on appropriate reported How many actual illicit response to such incidents. discharges determined? #25. Stormwater Page on Website See BMP #7 1. See BMP #7 1. See BMP #7 1. See BMP #7 DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 20 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 021-1.0153, the Town of Clayton relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 and the NCGO10000 permit for construction activities as qualifying alternative programs to meet the NPDES MS4 Permit requirements for all construction site runoff control measures to reduce pollutants in stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre and any construction activity that is part of a larger common plan of development that would disturb one acre or more. Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Penult Legal Meets Whole Reference State or Local Program Name Authority Implementing Entity or Part of Requirement 3.5.1 - Town of Clayton 15A NCAC Town of Clayton Whole 3.5.4 Delegated SPCA Program* Chapter 04 * The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at: hitps:HcodelibLaa.amlegal.com/codes/clqytonnc/latest/clqyton nc/0-0-0-257044JD Chapter156. The Town of Clayton also implements the following BMPs to meet NPDES MS4 Permit requirements. Table 17: Construction Site Runoff Control BMPs Permit 3.5.6: Public Input Ref. Measures to provide and promote a means for the public to notify the appropriate authorities of observed erosion and sedimentation problems. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric #26. Municipal Staff Training Train municipal staff who receive 1. Train municipal staff 1. Annually 1. Number of staff calls from the public on the protocols on proper handling of trained. for referral and tracking of construction site runoff construction site runoff control control complaints. complaint . #27. Stormwater Engineer The Stormwater Engineer is trained 1. Complaints will be 1. Annually 1. How many EC to assist in educating public on documented in complaints were erosion control issues and on spreadsheet. received? appropriate response to such concems. Permit 3.5.5: Waste Management Ref. Measures to require construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to water quality. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 21 Table 17: Construction Site Runoff Control BMPs A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric #28. Maintain Legal Authority Waste Management on construction 1. See BMP #18 1. See BMP #18 1. See BMP #18 sites is captured in the illicit discharge ordinance and can be used as a mechanism of enforcement. DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 22 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 Town of Clayton 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 Town of Clayton 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-IV) 15A NCAC 2B Town of Clayton Code of .0620 - .0624 Ordinances — Chapter 155 (155.501) Neuse River Basin Nutrient Sensitive 15A NCAC 213.0235 Town of Clayton Code of (NSW) Management Strategy Ordinances — Chapter 158 DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 23 The following map illustrates the boundaries of the Water Supply Watershed: Smitht&A WSW Johnston County WSW Clayton Town Limits Extra -Territorial Jurisdiction r i 9y� b v K C.v 1 2 3 M lea The Town of Clayton 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 NCS000559 SWMP Town of Clayton January 1, 2022 Page 24 Table 19: Summary of Existing Post -Construction Program Elements Permit Requirements for Municipal Ordinance/Code Reference(s) Date Adopted Plan Review and Approval and/or Document Title(s) 3.62(a) Authority Town of Clayton Code of Ordinances — Adopted Chapter 158 (158.002) 11/16/20; effective 1/1/21 3.6.3(a) & 15A NCAC 02H.0153(c) Town of Clayton Code of Ordinances — " Federal, State & Local Projects Chapter 158 (158.003) 3.6.3(b) Plan Review Town of Clayton Code of Ordinances — " Chapter 158 (158.026) 3.6.3(c) O&M Agreement Town of Clayton Code of Ordinances — " Chapter 158 (158.061) 3.6.3(d) O&M Plan Town of Clayton Code of Ordinances — " Chapter 158 (158.060) 3.6.3(e) Deed Town of Clayton Code of Ordinances — " Restrictions/Covenants Chapter 158 (158.043) 3.6.3(f) Access Easements Town of Clayton Code of Ordinances — " Chapter 158 (158.067) Permit Requirements for Municipal Ordinance/Code Reference(s) Date Adopted Inspections and Enforcement and/or Document Title(s) 3.62(b) Documentation Town of Clayton Code of Ordinances — Adopted Chapter 158 (158.060) 11/16/20; effective 1/1/21 3.62(c) Right of Entry Town of Clayton Code of Ordinances — " Chapter 158 (158.061) 3.6.4(a) Pre -CO Inspections Town of Clayton Code of Ordinances — " Chapter 158 (158.081) 3.6.4(b) Compliance with Plans Town of Clayton Code of Ordinances — " Chapter 158 (158.027) 3.6.4(c) Annual SCM Inspections Town of Clayton Code of Ordinances — " Chapter 158 (158.060) 3.6.4(d) Low Density Inspections Town of Clayton Code of Ordinances — " Chapter 158 (158.060) 3.6.4(e) Qualified Professional Town of Clayton Code of Ordinances — " Chapter 158 (158.027) DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 25 The annual reporting metrics for the post construction program are provided in Table 20: Post Construction Site Runoff Control BMPs below. Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post -Construction Reporting Requirements Ref. Measures to document activities over the course of the fiscal year (July 1 — June 30) including appropriate information to accurately describe ro ress, status, and results. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #29. Standard Reporting Implement standardized tracking, 1. Track number of low 1. Continuously 1. Number of plan documentation, inspections and density and high density reviews performed for reporting mechanisms to compile plan reviews performed. low density and high appropriate data for the annual self- density. 2. Track number of low 2. Continuously 2. Number of plan assessment process. Data shall be provided for each Post -Construction/ density and high density approvals issued for low Qualifying Alternative Program plans approved. density and high density. being implemented as listed in Tables 3. Maintain a current 3. Continuously 3. Summary of number 18 and 19. inventory of low density and type of SCMs added projects and constructed to the inventory; and SCMs including SCM number and acreage of type or low density low density projects acreage, location and last constructed. inspection date. 4. Track number of SCM 4. Continuously 4. Number of SCM inspections performed. inspections. 5. Track number of low 5. Continuously 5. Number of low density density inspections inspections. performed. 6. Track number and 6. Continuously 6. Number and type of type of enforcement enforcement actions actions taken. taken. Permit 2.3 and 3.6: Qualifying Alternative Program(s) Ref. Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state program requirements. BMP A B C D No. 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 NCS000559 SWMP Town of Clayton January 1, 2022 Page 26 Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.2: Legal Authority Ref. Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review designs and proposals for new development and redevelopment to determine whether adequate stormwater control measures will be installed, implemented, and maintained, (b) request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post -Construction Stormwater Management Program, and (c) enter private property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater discharges to determine whether there is compliance with the Post -Construction Stormwater Management Program. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric This permit requirement is fully met by the existing post -construction program, see references provided in Table 19 Permit 3.6.3: Plan Review and Approval Ref. 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 . 10 17 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 A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric This permit requirement is fully met by the existing post -construction program, see references provided in Table 19 Permit 3.6.4: Inspections and Enforcement Ref. Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post - construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy. Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s), (b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require that inspections be conducted by a qualified professional. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric This permit requirement is fully met by the existing post -construction program, see references provided in Table 19 DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 27 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the Town of Clayton municipal facilities and operations. Pollution prevention and good housekeeping is accomplished through the implementation of seven required programs, which collectively address the ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and open space maintenance, fleet and building maintenance, new construction and land disturbances, and municipal storm sewer system maintenance. Pollution prevention and good housekeeping for municipal operations includes the following programs: 1. Municipal Facilities Operation and Maintenance Program 2. Spill Response Program 3. MS4 Operation and Maintenance Program 4. Municipal SCM Operation and Maintenance Program 5. Pesticide, Herbicide and Fertilizer Management Program 6. Vehicle and Equipment Maintenance Program 7. Pavement Management Program The Town of Clayton will manage, implement and report the pollution prevention and good housekeeping BMPs as specified in Table 21 below for each required program. Table 21: Pollution Prevention and Good Housekeeping BMPs Permit 3.7.1: Municipal Facilities Operation and Maintenance Program Ref. Measures to manage facilities that are owned and operated by the permittee and have the potential for 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 imp ementing pollution prevention and good housekeeping ractices. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric #30. Staff Training Provide staff training to prevent and 1. Identify staff to be 1. Year 1 1. How many Town staff reduce stormwater pollution from trained are identified to be activities such as park and open space trained? 2. Schedule staff training 2. Annually 2. How many Town staff maintenance, fleet and building maintenance, new construction and sessions were trained? land disturbance, and stormwater system maintenance. #31. Inventory of Town owned or operated facilities DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 28 Table 21: Pollution Prevention and Good Housekeeping BMPs Maintain inventory of facilities and 1. Record of Facilities 1. Year 1 1. How many facilities operations owned and operated by the does the Town own? Town with the potential for generating polluted stormwater runoff. #32. Inspection and Maintenance of Town Facilities Maintain and implement and 1. Identify inspections 1. Year 1 1. Number of inspections Inspection and Maintenance Program. needed. required? 2. Perform identified 2. Annually 2. Number of inspections inspections.performed? 3. Perform maintenance 3. Annually 3. Number of as needed per maintenance needs inspections. identified? Permit 3.7.2: Spill Response Program Ref. Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response rocedures. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #33. Staff Training Provide staff training for those in 1. Identify facilities and 1. Annually 1. Number of facilities positions that may need to respond to staff which require such and associated staff that contaminated stormwater runoff. training. need training? 2.Train staff 2. Annually 2. How many staff were trained? #34. Standard Operating Procedures for Spill Response Develop written SOP(s) for various 1. Identify the various 1. Year 1 1. How many SOP(s) are spill responses. situations. needed? 2. Assign staff to develop 2. Year 2 2. Has staff been SOP(s) assigned to develop SOP(s) 3. Write SOP(s) 3. Year 3 3. Are SOP(s) documented? Yes/No/Status Permit 3.7.3: MS4 Operation and Maintenance Program Ref. Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections, maintain the collection system including catch basins and conveyances; and establish specific frequencies, schedules, and standard documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #35. Staff Training DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 29 Table 21: Pollution Prevention and Good Housekeeping BMPs Provide staff training for field 1. Identify field 1. Annually 1. How many staff are to personnel on stormwater awareness, personnel to be trained. be trained for MS4 illicit discharge/pollution prevention. O&M? 2. Provide training 2. Annually 2. How many staff were trained? #36. System Inspections Establish specific frequencies, 1. Establish schedule and 1. Year 1 1. Has schedule and map schedules, and documentation of mapping for routine been established? MS4 inspections of catch basins, inspections Yes/No/Status 2.Perform routine 2. Annually 2. How many inspections drop inlets and conveyances. inspections as scheduled wereperformed? 3. Identify system 3. Annually 3. How many repairs maintenance/repair needs were identified? 4. Schedule necessary 4. Annually 4. How many repairs system maintenance were completed? Permit 3.7.4: Municipal SCM Operation and Maintenance Program Ref. Measures to manage municipally -owned, operated, and/or maintained structural SCMs that are installed for compliance with the permittee's post -construction program. The permittee shall maintain a current inventory of SCMs, perform SCM ins ections and maintenance, and shall establish specific frequencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #37. SCM Inventory and Inspection Develop inventory and inspection 1. Complete Clayton 1. Year 1 1. How many SCMs does schedule of Town owned SCMs owned SCM inventory the Town own? 2. Develop 2.Year 1 2. Provide inspection annual/routine inspection schedule schedule for Clayton SCMs #38. SCM Maintenance Perform and document routine 1. Perform routine 1. Continuously 1. How many inspections inspections and maintenance of Town inspections wereperformed? owned SCMs 2. Document inspections 2. Continuously 2. How many repairs and repair needs were scheduled and performed? Permit 3.7.5: Pesticide, Herbicide and Fertilizer Management Program Ref. Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine pollution prevention and chemical use, storage and handling training, and shall ensure compliance with permits and a licator certifications. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #39. Staff Training Require staff training for those 1. Identify staff 1. Year 1 1. How many staff need involved with pesticide, herbicide, responsible for such to be trained? and fertilizer applications. duties DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 30 Table 21: Pollution Prevention and Good Housekeeping BMPs 2. Identify appropriate 2. Year 1 2. How many staff training opportunities obtained and certifications training/certification? Permit 3.7.6: Vehicle and Equipment Maintenance Program Ref. Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #40. Staff Training Educate staff on preventing and 1. Identify NPDES 1. Year 1 1. How many NPDES minimizing contaminated stormwater industrial permits held by industrial permits does runoff in addition to ensuring the Town. the Town hold? 2. Identify staff to be 2. Year 1 2. How many Town staff municipal industrial facilities are meeting requirements of NPDES trained need to be trained? industrial permit(s) 3. BMP #35 3. BMP #35 3. BMP #35 #41. Oil Recycling Recycle oil used for vehicle and 1. Number of gallons of 1. Annually 1. Number of gallons of equipment needs oil recycled oil recycled? Permit 3.7.7: Pavement Management Program Ref. Measures to reduce pollutants in stormwater runoff from municipally -owned streets, roads, and parking lots within the permittee's corporate limits. The permittee shall implement measures to control litter, leaves, debris, particulate and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #42. Street Sweeping Develop schedule for routine street 1. Develop map with 1. Year 1 1. Completed sweeping of Town maintained streets Town maintained streets which have curb and gutter systems with curb and gutter 2. Develop schedule and 2. Year 2 2. Has schedule and routes for routine street routes been established? -sweeping 3. Implement routine 3. Year 3 3. How many miles of street sweeping streets have been swept? #43. Leaf Collection Periodic collection of leaves from 1. Develop contract for 1. Year 1 1. Volume of leaves residential and public areas to reduce annual leaf collection by collected? pollutants and clogging of storm a third party system inlets DRAFT NCS000559 SWMP Town of Clayton January 1, 2022 Page 31