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HomeMy WebLinkAboutJ4-Third Fork Creek TMDL Response Plan_FINALTotal Maximum Daily Load Response Plan for Turbidity & Total Suspended Solids in Third Fork Creek (Cape Fear River Basin), Durham, North Carolina CITY OF DURHAM Prepared by the Public Works Department, Stormwater & GIS Services Division March 19, 2019 101City Hall Plata, Third Floor, Durham, NC 27701 919.560.4326 I DUrhamNC,gov follow Us @CftV0f0Urh0MNC TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 The City of Durham's Water Quality Group in the Division of Stormwater & GIS Services and the Department of Public Works developed this TMDL Response Plan for the City of Durham. The City would like to acknowledge contributions to this TMDL Response Plan from several City and County government departments and divisions. CITY OF DURHAM City -County Planning Code Enforcement Landus Robertson Public Works Department Stormwater & GIS Services Jonathan Baker Michelle Woolfolk J.V. Loperfido Emily Rhode Jim Azarelo Patrick Hogan Sandra Wilbur Lance Fontaine Laura Smith Megan Walsh Jennifer Buzun Brajesh Tiwari Water Management Department Water & Sewer Maintenance Kerry Sanford Kenny Willard Jeremy Farlow DURHAM COUNTY ACKNOWLEDGMENTS Unified Development Ordinance Mike Stock Bo Dobrzenski Danny Cultra Operations Phillip Powell Bruce Woody John Sandin Mike Boyd Industrial Waste Control Tyrone Battle Engineering and Environmental Services Department Stormwater & Erosion Control Utilities Ryan Eaves Stephanie Brixey McKenzie Gentry Public Health Department Environmental Health Patrick Eaton Noelle Spence Soil & Water Conservation District Heather Dutra 2 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Table of Contents 1. Acronyms and Abbreviations........................................................................................................................... 4 2. Executive Summary.......................................................................................................................................... 5 3. TMDL Response Plan Objective....................................................................................................................... 6 4. Introduction and Background.......................................................................................................................... 6 4.1. Watershed Information............................................................................................................................ 8 4.2. Jurisdictional Responsibility...................................................................................................................11 5. Pollutant Sources...........................................................................................................................................11 5.1. In -stream Sediment Sources.................................................................................................................12 5.2. Construction/Development Sources of Sediment................................................................................12 5.3. Runoff from Impervious Surfaces and Direct Discharge.....................................................................13 6. Pollution Prevention and Mitigation Measures Currently Being Implemented...........................................13 6.1. Response Plan Measure Definitions.....................................................................................................13 7. Newly Proposed Pollution Prevention and Mitigation Measures.................................................................16 7.1 Measures to Reduce In -stream Sediment Sources..............................................................................16 7.2 Measures to Reduce Construction Sources of Sediment....................................................................17 7.3 Measures to Reduce Other Sources of Sediment................................................................................18 8. Prioritized Measures Applicable to the NPDES Six Minimum Measures....................................................21 8.1. Implementation of Plan to the Maximum Extent Practicable..............................................................21 8.2. Public Education and Outreach.............................................................................................................21 8.3. Public Participation and Involvement....................................................................................................21 8.4. Illicit Discharge Detection and Elimination...........................................................................................22 8.5. Construction Site Stormwater Runoff Control......................................................................................22 8.6. Post -Construction Stormwater Management........................................................................................23 8.7. Pollution Prevention/Good Housekeeping for Municipal Operations.................................................23 9. Watershed Planning.......................................................................................................................................23 10. Water Quality Assessment and Monitoring...............................................................................................24 10.1. Water Quality Monitoring....................................................................................................................24 10.2. Turbidity Data and Computed TSS Loads.........................................................................................27 11. Water Quality Co -Benefits of TMDL Response Plan Implementation......................................................27 11.1. Value Added to Removal of Nutrients and Metals...........................................................................27 11.2. Benefits to Aquatic Life......................................................................................................................28 12. Steps Towards TMDL Response Plan Implementation............................................................................28 12.1. Response Plan Schedule by Agency..................................................................................................28 12.2. Tracking and Data Collection.............................................................................................................30 12.3. Re-evaluation of Response Plan........................................................................................................30 13. References..................................................................................................................................................30 3 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 14. Appendix A: Summary Table of All Proposed Measures (Priority and Non-Priority)................................32 15. Appendix B: Summary Table of Measures Not Included in the TMDL Response Plan ..........................35 16. Appendix C: Measure of Incremental Progress........................................................................................36 List of Tables Table 1. Approved TMDL for the Third Fork Creek Watershed............................................................................. 8 Table 2. Measures currently implemented in the Third Fork Creek watershed................................................15 Table 3. Prioritized Measures in the Third Fork Creek watershed.....................................................................20 Table 4. NCDEQ 2016 Final 303(d) List (NCDEQ 2016), Category 5 Assessments for Third Fork Creek ........ 27 Table 5 Priority and non -priority measures proposed for the Third Fork Creek TMDL Response Plan.............32 Table 6. Measures considered and not currently feasible for implementation in the Third Fork Creek TMDL ResponsePlan........................................................................................................................................................35 Table 7 Preliminary list of incremental progress.................................................................................................36 List of Figures Figure 1. Map of the Third Fork Creek Watershed in City of Durham with the impaired segment shown in red. ................................................................................................................................................................................... 7 Figure 2. 2018 Existing Land Use in the Third Fork Creek watershed...............................................................10 Figure 3. Sediment generation, fate, and transport conceptual model.............................................................12 Figure 4. City of Durham, UCFRBA, and DWR ambient stream monitoring sites in the Third Fork Creek watershed............................................................................................................................................................... 26 1. Acronyms and Abbreviations ■ CPV - Channel Protection Volume ■ CWEP - Clean Water Education Partnership ■ DWR - Division of Water Resources ■ EPA - Environmental Protection Agency ■ IDDE - Illicit Discharge Detection and Elimination ■ LA - Load Allocation ■ LID - Low Impact Development ■ NCAC - North Carolina Administrative Code ■ NCDEQ - North Carolina Department of Environmental Quality ■ NPDES - National Pollutant Discharge Elimination System ■ NTU - Nephelometric turbidity units ■ MS4 - Municipal Separate Storm Sewer System ■ SCM - Stormwater Control Measure ■ TMDL - Total Maximum Daily Load ■ TSS - Total Suspended Solids n TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 ■ UCFRBA - Upper Cape Fear River Basin Association ■ USGS - United States Geological Society ■ WIP - Watershed Improvement Plan ■ WLA - waste load allocation 2. Executive Summary The City of Durham's Stormwater Quality Group in the Department of Public Works and Division of Stormwater & GIS Services developed this Total Maximum Daily Load (TMDL) Response Plan to address water quality impairments in Third Fork Creek due to elevated levels of turbidity and total suspended solids (TSS). The TSS TMDL for Third Fork Creek was issued in 2005 by the North Carolina Department of Environmental Quality (NCDEQ) and approved by the U.S. Environmental Protection Agency (EPA). A TMDL sets the allowable pollutant loads for a waterbody so that actions may be taken to reduce point and nonpoint source pollution in order to meet State water quality standards (USEPA, 1991). The Third Fork Creek watershed covers an area of 16.6 square miles and is entirely within Durham's municipal limits. The watershed includes a large portion of the older and highly developed downtown section of the City. A 3.6-mile segment of Third Fork Creek is listed as impaired by turbidity; however, the pollutant reductions for this TMDL are expressed as pounds per year of TSS. Turbidity is a measurement to determine the cloudiness of stream water. Suspended sediment in streams that cause turbidity can be quantified as a concentration measurement of the total mass of solids per a unit volume of stream water (e.g., mg TSS / L). Suspended sediment in Third Fork Creek comes from in -stream erosion of channel banks and stream beds, erosion and transport due to earth -moving activities (e.g., construction site grading), and is present in runoff discharged to storm sewer systems. This response plan is the product of several brainstorming and planning meetings in 2018 involving input from multiple City and County Departments. This response plan outlines the prevention and mitigation measures that City and County staff will implement to achieve reductions of turbidity and TSS concentrations in Third Fork Creek. A prevention measure stops releases of pollutants from happening and a mitigation measure removes pollutants once they have been released. The actions described in this plan focus on ways to reduce sediment from in -stream sources (e.g., streambank erosion), construction sources (e.g., new development and re -development), and other sources. The recommended prioritized actions that address in -stream sources include streambank restoration and stabilization, stream channel volume protection for new development, and stream walks to identify eroding and collapsed streambanks. The prioritized actions that target sediment from construction activity include using flocculants in construction site ditches, increased sediment and erosion control inspections, stop -work orders for non -compliant small construction sites (<12,000 square feet), and using storm drain protection materials for street maintenance work. The prioritized actions that address sediment and turbidity from other sources include conducting a media campaign, increased street sweeping, adding green infrastructure to complement traditional stormwater control measures (SCMs), prioritizing the construction of SCMs identified in the Third Fork Creek Watershed Improvement Plan (WIP) that reduce turbidity and sediment, and steep slope protection on site development projects. The actions described in this response plan are estimated to be implemented over three permit cycles (within 15 years). There are five actions estimated to be implemented within the current permit cycle (2018- 2023), there are four actions that may be implemented within 5-10 years (2018-2028), and three actions estimated to be implemented within 10-15 years (2018-2033). The City's Public Works Department will be responsible for communicating with the appropriate departments, divisions, and workgroups to identify the metrics and data needed to track the progress of measures outlined in this response plan. As resources allow, the City's Public Works Department will re-evaluate the measures outlined in this response plan on a 5 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 five-year basis and will continue to provide progress updates on an annual basis as part of the National Pollutant Discharge Elimination System (NPDES) Municipal Stormwater Permit annual reporting cycle. 3. TMDL Response Plan Objective The objective of this TMDL Response Plan is to identify and implement measures that will reduce the levels of turbidity and TSS in Third Fork Creek within the City limits of Durham, North Carolina. This TMDL Response plan addresses the City of Durham's assigned municipal separate storm sewer system (MS4) waste load allocation (WLA) documented in the 2005 EPA -approved TMDL for Third Fork Creek. In addition, this TMDL Response Plan is required under Section J of the City of Durham's National Pollutant Discharge Elimination System (NPDES) Municipal Stormwater Permit (No. NCS00249). This response plan incorporates ideas from multiple stakeholders that have a vested interest in complying with state and federal regulations as well as reducing the TMDL pollutants of concern and improving overall water quality in the Third Fork Creek watershed. The proposed prevention and mitigation measures aim to reduce turbidity/TSS levels using a variety of tools that address the multiple sources and transport pathways of the pollutant of concern. The variety of tools used in this plan is leveraged by the stakeholder groups' diverse regulatory authority and capabilities. As a result, the stakeholders included in this response plan have the ability to implement some but not all of the proposed prevention and mitigation measures. No one entity, including the City of Durham Public Works Department, has the ability to remedy the turbidity/TSS levels individually, given the nature of the issue. 4. Introduction and Background The City of Durham is subject to an approved TMDL with waste load allocations in the Third Fork Creek watershed, in the Cape Fear River Basin. In 2002, the North Carolina Department of Environmental Quality (NCDEQ, formerly NCDENR) identified a 3.6-mile segment of Third Fork Creek as impaired by turbidity (NCDENR, 2003a). Figure 1 shows the impaired segment of Third Fork Creek highlighted in red. A TSS TMDL for Third Fork Creek was approved in 2005 (Table 1). The pollutant reductions for this TMDL are expressed as pounds per year of TSS. A maximum TSS load of 0.75 tons per day is required in Third Fork Creek. A WLA of 0.36 tons TSS per day was assigned to the City of Durham MS4 area and a Load Allocation (LA) of 0.39 tons TSS per day was assigned to nonpoint sources in the Third Fork Creek watershed, which are all located within the City of Durham. Both point and nonpoint sources were considered and margins of safety were included in the WLA and LA listed above. The final EPA -approved TMDL document can be found on the North Carolina Department of Environmental Quality (NCDEQ) website at the link below: https://files.nc.gov/ncdeq/Water%200uality/Planning/TMDL/FINAL%20TMDLS/Cape%20Fear/Haw%2CDe ea%2Cetc.TurbidityFecalTM DL.pdf n. TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 ----- Ner54rw � �Granvi r i r Drange Durham t Ellerbe Creek _ Jordan f Third Lake ; Fnrk l Creek Watershed Chatham Mike Sandy Headwaters Creek New Hope Creek * Hope Creek Little Northeast Creek =County Boundary Impaired Waters. IN City Limits—(NCDEQ 2016 PIT Assessment) =Watersheds CITYDF Streams 0 0-6 1 2 DURHAM Tributaries Miles Figure 1. Map of the Third Fork Creek Watershed in City of Durham with the impaired segment shown in red. 7 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Table 1. Approved TMDL for the Third Fork Creek Watershed Description of area DWR Assessment Stream TMDL Parameter TMDL EPA Approval Date Unit(s) Classification(s) Third Fork Creek from 16-41-1-12-(2) WS-IV NSW. TSS 0.75 tons per January 11, 2005 two miles upstream of Potable water day of TSS Highway 54 to New supply, Nutrient Hope Creek. Sensitive Water NSW. Nutrient Sensitive Water WS. Water Supply classification The TSS TMDL for Third Fork Creek was developed because stream monitoring data exceeded the Fresh Surface Water Quality Standards for Class C Waters under Title 15A, Subchapter 213 of the North Carolina Administrative Code (NCAC). Under 15A NCAC 02B .0211(21), the water quality standard for turbidity is stated as follows: The turbidity in the receiving water shall not exceed 50 Nephelometric Turbidity Units (NTU) in streams not designated as trout waters and 10 NTU in streams, lakes, or reservoirs designated as trout waters; for lakes and reservoirs not designated as trout waters, the turbidity shall not exceed 25 NTU; if turbidity exceeds these levels due to natural background conditions, the existing turbidity level shall not be increased. Compliance with this turbidity standard can be met when land management activities employ Best Management Practices (BMPs) has defined by Rule .0202 of this Section] recommended by the Designated Nonpoint Source Agency [as defined by Rule. 0202 of this Section]. BMPs shall be in full compliance with all specifications governing the proper design, installation, operation, and maintenance of such BMPs. The water quality standard for turbidity is the target that will be used to evaluate the effectiveness of the measures in this TMDL Response Plan with the overall goal to reduce TSS loads in Third Fork Creek. Annual updates on progress toward improving turbidity levels and TSS concentrations in Third Fork Creek are provided in the City of Durham NPDES Municipal Stormwater Permit Annual Report. Third Fork Creek is also within the B. Everett Jordan Lake watershed. A chlorophyll a TMDL for Jordan Lake was approved in 2007. The pollutant reductions for this TMDL are expressed as 336,079 pounds per year of total nitrogen and 23,106 pounds per year of total phosphorus. Target reductions are not expressed specifically for Third Fork Creek but are expressed as loads to the Upper New Hope Arm of Jordan Lake. Full implementation of the measures enclosed in this TMDL Response Plan will be enabled as resources allow. Potential barriers to full implementation include budget constraints, staffing levels, and employee turnover in departments designated for executing the response plan measures. Some measures presented in this TMDL Response Plan require significant monetary resources and thus, are highly dependent on the city budget conditions. The ability to secure support and approval for proposed measures from City Council and management could potentially influence project schedules. Implementation of this response plan also depends on coordination and effective partnership with organizations outside of the City of Durham. 4.1. Watershed Information The Third Fork Creek watershed covers an area of 16.6 square miles and is entirely within Durham's municipal limits. The watershed includes a large portion of the older and highly developed downtown section of the City. The creek flows through the heart of many Durham neighborhoods like Tuscaloosa -Lakewood, St. Teresa, Forest Hills, Hope Valley Farms, and Woodcroft, down to New Hope Creek, which flows into Jordan Lake. The northern edge or boundary of the watershed lies in downtown Durham, just north of the Durham Freeway (NC 147), and the southern edge or boundary is close to Interstate 40. The downstream portion of the watershed contains areas of protected lands, including the game lands associated with Jordan Lake. A map of the watershed and the impaired section of Third Fork Creek is provided in Figure 1 and a map of existing land use types in the Third Fork Creek watershed is shown in Figure 2. Land use in the Third Fork Creek watershed is predominantly a combination of residential development, a dense downtown commercial : TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 center, and unmanaged open space. Residential land cover is generally higher -density in the northern portion of the watershed near downtown Durham and lower -density toward the southern mouth of the watershed. A significant amount of impervious surface associated with transportation networks, downtown areas, and commercial land uses exists in the north/northeast portion of the watershed. A majority of the development in the upper and middle portions of the watershed occurred prior to the more robust SCM controls that are now used with new development. Unmanaged open space and a wildfowl impoundment lie adjacent to the main stem of Third Fork Creek in the middle and downstream portions of the watershed. 9 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Headwaters New Ho a Creek 17 'r ;t 1As AW chi TH"rr F0. k re$k t - _ streams r L _ InterstatelUSINC Highway Watersheds .� Land Use `r' t Agricultural w Commercial I High -Den. Residential Industrial Low -Den- Residential i} J - Medium -Den Residential - Off ice - Vacant Public Lands - Parks IOpen Space - Utility - Vacant Apartment- Residential City Limits Third Fork Creek 0 0-5 1 2 N Land Use Map mmiles CITY 0__ oueHnM Figure 2. 2018 Existing Land Use in the Third Fork Creek watershed 10 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 4.2. Jurisdictional Responsibility The City of Durham, Durham County, and North Carolina State government have regulatory authority for controlling the various pathways that sediment can reach Third Fork Creek. These agencies have responsibilities for implementing different prevention and mitigation measures described in this TMDL Response Plan. City of Durham Departments Within the Public Works Department are the Stormwater & GIS Services Division, the Engineering Services Division, and the Operations Division. The Stormwater & GIS Services Division is responsible for managing the following NPDES permit programs: Pollution Prevention & Good Housekeeping, Illicit Discharge Detection and Elimination, Public Education & Outreach, Public Participation & Involvement, and Post -Construction Stormwater Management. Stormwater Infrastructure and Watershed Planning are also included in this division. The Stormwater Development Review Group and the Engineering Services Division are responsible for reviewing development plans. The Operations Division is responsible for the City's street sweeping program and maintaining the City's streets and storm drainage system. Durham County Departments The Engineering and Environmental Services Department's Stormwater and Erosion Control Division is responsible for managing the County's stormwater program and inspecting private construction sites. The Durham Soil and Water Conservation District manages and secures grants for stream restoration projects and helps protect local water quality by providing consultations and funding for residential landscape erosion and drainage projects. Durham City -County Departments The Planning Department's Zoning Enforcement Division inspects many properties for code violations and notifies the City Stormwater & GIS Services Division and the County Stormwater and Erosion Control Division when sediment and erosion control problems or violations are observed during field investigations. The Unified Development Ordinance (UDO) group is responsible for amending the City -County LIDO and ensuring compliance with the UDO, which may include measures that prevent or mitigate sources of sediment. The Planning Department also investigates stream buffer violations and enforces the LIDO stream buffer requirements in the Cape Fear River Basin. North Carolina State Government Departments The Department of Environmental Quality's Division of Water Resources is responsible for investigating stream buffer violations in the Neuse River Basin and enforcing State regulations when sediment discharges from construction sites impact downstream surface waters. The Department of Environmental Quality's Division of Energy, Mineral and Land Resources is responsible for issuing NPDES MS4 permits, which provide regulatory guidance for developing and implementing TMDL response plans. 5. Pollutant Sources Suspended sediment is the primary cause of high turbidity levels in Third Fork Creek and has many different sources throughout the watershed. Both human and natural processes contribute to the amount of sediment directly discharged to and mobilized within the stream. A large amount of sediment in Third Fork Creek is generated from and transported in nonpoint source stormwater runoff. This includes runoff from impervious surfaces (e.g., streets, roofs) and from pervious surfaces through the erosion of soil. Areas where land is disturbed, like grading or cleared land on construction sites, can also be significant sources of sediment. Increased impervious cover added throughout a watershed also leads to increased peak flow rates in streams during storm events and generates higher scouring forces that accelerate stream bank erosion. Vegetation in stream riparian areas can naturally filter out sediment from overland storm flows and help 11 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 stabilize soil in stream banks and floodplain areas while alterations and removal of riparian vegetation can contribute to higher sediment and turbidity levels in Third Fork Creek. Discharges of sediment and turbid substances from municipal facilities, industrial facilities, and construction sites to storm sewer networks and stream channels directly contribute sediment to Third Fork Creek. Land *nl disturbance Industrial discharge Erasion Municipal discharge Upstrearn impoundment Increased sediment Altered Land use I Increased Channel Riparian area runoff vol, alteration disturbance Strearnhank Impaundment Increased stream erosion management kinexic energy Mobilization of bank delivery to stream & channel sediment Elevated Levels of Suspended Sediment I Turbidity) Excess Light Scattering Phytoplankxon- nutrients I Fish, insects and aquatic bivalves ,4dapted from SPA 2007 CADblS amceptuo� made stress or mortality Figure 3. Sediment generation, fate, and transport conceptual model. 5.1. In -stream Sediment Sources During storm events, peak flows can lead to elevated sediment transport in stream systems like Third Fork Creek. These peak flows and fast stream velocities create high shear stress that can mobilize sediment already in the stream. For example, relatively high shear stresses were associated with high -gradient meander bends in a Piedmont watershed located in Maryland (Nelson et al., 2006). Stream banks can also collapse as a part of channel erosion with wider stream channels observed in urban (as opposed to rural) streams in the southern United States (0'Driscoll et al, 2010). Peak stormwater flows can also cause channel incision of stream beds with erodible material, like clays and silts, to a greater extent in urban streams as compared to rural streams (0' Driscoll et al., 2010). These highly erodible soils are present in the Third Fork Creek watershed. 5.2. Construction/Development Sources of Sediment In addition to in -stream sources of sediment, upland and floodplain areas can be important factors in watershed sediment transport. A watershed sediment -budget study conducted in Maryland noted that 12 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 upland erosion can be a significant source of sediment in streams (Allmendinger et al., 2007). Land disturbance activities including digging, grading, and earth -moving associated with development projects or repair projects can make upland soils particularly susceptible to erosion. A recent increase in directional drilling operations associated with the installation of underground fiber optic cables in the City of Durham has led to more incidents of sediment and turbid water reaching the City's MS4 and streams, including Third Fork Creek. Riparian areas act as critical barriers that prevent sediment transport to streams - alteration of these areas during land disturbance activities can enable a significant amount of sediment to reach local stream channels. 5.3. Runoff from Impervious Surfaces and Direct Discharge Sediment reaching storm sewer networks through direct discharge or in runoff from impervious surfaces can contribute to instream turbidity issues and higher TSS loading. Sediment can come from sources including municipal facilities, soil erosion on residential properties, and sediment associated with commercial facilities, industrial site facilities, and accumulated material on impervious surfaces like streets and parking lots. This sediment is washed off of impervious surfaces and can be transported through storm drain networks to local streams. 6. Pollution Prevention and Mitigation Measures Currently Being Implemented 6.1. Response Plan Measure Definitions The measures described in this TMDL Response Plan fall into two main categories: Prevention and Mitigation. The definitions below apply to this plan and may be reviewed and modified in future revisions of this plan. A prevention measure is defined as a management practice, procedure, requirement or other action that can stop a release of pollution from happening. For Third Fork Creek, prevention measures are designed to target sediment at its source by preventing sediment from reaching the storm drainage system and surface waters. Prevention measures prioritized in Third Fork Creek include: ■ Conducting media campaigns to motivate the public to take specific actions that reduce sources of sediment ■ Providing sediment and erosion control materials to City Public Works crews ■ Managing steep slopes for development projects A mitigation measure is defined as a practice, control measure, technology, requirement, or other action that can remove pollution once it has been released, reached the storm drainage system, or reached surface waters. For Third Fork Creek, mitigation measures are designed to contain or remove sediment and decrease in -stream turbidity. Mitigation measures prioritized in Third Fork Creek include: ■ Implement stream restoration and streambank stabilization projects ■ Increasing the frequency of street sweeping ■ Enable utilization of green infrastructure to complement traditional SCMs in post -construction stormwater management strategy ■ Install SCMs that address TSS and turbidity in developed areas ■ Utilization of flocculants in drainage ditches on construction sites In addition to identifying new mitigation and prevention measures, the 2018 brainstorming sessions held by the Stormwater & GIS Services Division also identified measures that are currently being implemented by City and County departments and may not have been reported in the previous NPDES annual reports. Table 13 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 2 below shows the list of seven measures that were discussed during the brainstorming sessions and are currently implemented in the Third Fork Creek watershed. The next step is to communicate with each responsible department about the best method for collecting and reporting the data in the TMDL Response Plan updates. 14 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Table 2. Measures currently implemented in the Third Fork Creek watershed Measure Current) Implemented Y p NPDES Minimum Measure Category g rY Estimated Impact on Reducing Sediment p g Group(s) Responsible for Implementation Jurisdiction City-wide street sweeping program (including Third Fork Creek). Pollution Prevention/Good Housekeeping for High Public Works Operations City Municipal Operations Conduct monthly inspections on privately -funded construction sites. Promptly issue violations Construction Site Stormwater Runoff Control Medium -High Stormwater & Erosion Control County for off -site sediment discharges from active construction sites. Adherence to field crew protocols for sweeping and shoveling sediment in the street and curb Pollution Prevention/Good Housekeeping for Low -Medium Water Management - Water & Sewer City gutter during and after street water line repair work in order to prevent sediment from entering Municipal Operations Maintenance storm drains. Remove sediment from clogged storm drains prior to flushing storm drains which prevents Pollution Prevention/Good Housekeeping for Low -Medium Public Works Operations City more sediment from being released into a nearby stream. Municipal Operations Conduct site inspections monthly and conduct lot sweeping 1-2 times per month or as needed Pollution Prevention/Good Housekeeping for Low -Medium Public Works Operations City at the Public Works Operation Center (PWOC). Regularly check and replace sediment control Municipal Operations bags in stormwater catch basins at PWOC. Conduct routine inspections and maintenance of stormwater catch basins. Pollution Prevention/Good Housekeeping for Low Public Works Operations, Stormwater & City Municipal Operations GIS - Infrastructure Disturbed land must be stabilized with ground cover, devices, or structures sufficient to restrain Construction Site Stormwater Runoff Control Medium -High Stormwater & Erosion Control, Planning County, City -County erosion as described in the City -County Unified Development Ordinance (Section 12.10.4(B)). Conduct weekend enforcement patrols in the Third Fork Creek watershed. Illicit Discharge Detection and Elimination Low Public Works - Stormwater Quality - City IDDE 15 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 7. Newly Proposed Pollution Prevention and Mitigation Measures In 2018, the City's Water Quality Group met with workgroups in several City and County departments to discuss the TMDL Response Plan measures that were specific to their area of responsibility. There were several factors discussed during these meetings to help decide whether or not a measure could be implemented in the Third Fork Creek watershed. Some of the factors that were discussed and considered during the prioritization process include: ■ the estimated impact that the measure would have on reducing the amount of turbid water and sediment reaching Third Fork Creek and its tributaries; ■ the group(s) that would be responsible for implementing the measure; ■ the barriers to implementing the measure; ■ the implementation steps; ■ the amount of time (in years) it would take to implement the measure; ■ an approximate order -of -magnitude cost estimation; ■ the NPDES minimum measure category assigned to the measure, if any; and ■ whether or not the responsible group thought the measure should be included in the TMDL Response Plan The priority measures shown in Table 3 are discussed in this section and in Section 8 (grouped by the six minimum measures of the NPDES program). A table of all the priority and non -priority measures proposed for this TMDL Response Plan is found in Appendix A. The non -priority measures will not be implemented as part of this TMDL Response Plan, but they may be revisited and implemented as part of future revisions to this TMDL Response Plan. Appendix B lists all of the measures that were not included in the TMDL Response Plan due to factors such as the estimated high costs (>$500,000) for implementation, multiple barriers that could hinder implementation, the estimated low impact on reducing sediment, and the responsible group's willingness to include the measure in the response plan. A general measure that addresses all sources of sediment pollution is a media campaign to motivate the public to take specific actions that reduce sources of turbidity and sediment. This media campaign would include outlets such as the City website, online videos (e.g., YouTube), social media accounts, the Waterways newsletter, partnering with the Clean Water Education Partnership, and other methods. Staff members from Public Education and Pollution Prevention will collaborate on a media campaign. Outcome measures for the media campaign may be quantified using attendance numbers for in -person outreach events; metrics tracking views, likes, and shares of educational material posted on social media; and possibly surveying methods to gauge resident awareness of turbidity/TSS issues in Third Fork Creek. 7.1 Measures to Reduce In -stream Sediment Sources Intense stormwater runoff from impervious surfaces can cause stream banks to erode and collapse which adds sediment directly to the stream and increases turbidity levels. The measures in this section are intended to address stream bank sediment sources. Perform additional streambank stabilization and restoration. The Public Works Watershed Planning and Stormwater Infrastructure groups have previously completed a stream restoration project along Third Fork Creek. The proposed measure would expand on previous efforts and implement additional stream restoration in the Third Fork Creek watershed. The Watershed Improvement Plan (WIP) for Third Fork Creek was completed in December 2012 and identified several potential locations where stream restoration projects could be implemented. This measure would likely involve collaboration 16 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 between Public Works and other City departments in addition to non -city groups such as the Durham County Soil & Water Conservation District. Routine stream -walk program for Third Fork Creek; target main stem and tributaries with historically higher incidences of illicit discharges of sediment and also inspect and assess stream bank erosion. The City will establish a schedule and procedures for surveying sections of Third Fork Creek and its tributaries to identify turbid discharges and illicit discharges of sediment from the City's storm drain system. Stream -walk teams will inspect major outfalls that discharge to Third Fork Creek and its tributaries. The City's Stormwater Quality Group will perform the routine stream walks and communicate with County Stormwater and Erosion Control for issues related to construction site stormwater runoff control. The Stormwater Quality Group will also require responsible parties to clean up sediment discharges through enforcement of the Stormwater Management and Pollution Control Ordinance. Stream walk teams will also inspect stream banks for areas of active and potential erosion or bank instability. The location of problematic areas with high erosion potential will be shared with the Public Works Watershed Planning group to examine the feasibility of including these areas in future stream stabilization and restoration projects. Investigate highly effective channel protection methods to reduce streambank scour including stream channel protection volume (CPV) measures. If supporting evidence (e.g., data, technical reports, etc.) and justification to develop a channel protection requirement exists, the Public Works Stormwater Development Review group would propose modifications to design criteria for SCMs and submit proposed City code changes for public comment. The City would also ensure that the proposed design criteria and regulations comply with any State laws related to stormwater control measures for new development and redevelopment. Implementation of this measure would require public support and approval by Durham City Council. 7.2 Measures to Reduce Construction Sources of Sediment Promote the use of flocculants in drainage ditches on construction sites to settle out sediment and solids. The County Stormwater and Erosion Control Division would be responsible for researching the practice and developing design criteria for effective use in the field. This division would also pursue formal policy adoption and approval (e.g., Unified Development Ordinance changes). The Public Works Stormwater Quality group would create a one -page handout about flocculant guidance or update current construction handouts to include guidance on the use of flocculants. This educational material can be distributed to the contractors to keep the construction community up-to-date and informed on how to implement the use of flocculants as part of sediment and erosion control practices. Conduct more frequent sediment & erosion inspections and enforcement. The Durham County Stormwater and Erosion Control Division will aim to increase the annual number of sediment and erosion control inspections performed on active construction sites within Durham County. To date, the number of inspections has been limited by the number of sediment and erosion control inspectors that are on staff. The Stormwater and Erosion Control Division will increase the number of inspectors. Challenges to successfully implementing this measure include identifying qualified candidates and securing funding for additional positions. Change City code to grant authority for the City's Public Works Department to issue a "stop -work order" for small construction sites that are not in compliance with required sediment and erosion control practices. County sediment and erosion control inspectors do not have the authority to inspect small construction sites (<12,000 sf). The Public Works Stormwater Quality group will aim to gain authority to issue a "stop -work order" for small construction sites that are discharging sediment to the City's storm drain system. This effort will include developing and proposing text for modification of the ordinance, gaining approval for the change, and training staff and developing a workflow for the stop -work orders. 17 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 7.3 Measures to Reduce Other Sources of Sediment Conduct a media campaign to motivate the public to take specific actions that reduce sources of sediment and turbidity through the City's website, online videos (e.g. YouTube), social media accounts, Waterways newsletter, Clean Water Education Partnership (CWEP) handouts, and other methods. A media campaign will be undertaken to encourage the public to take specific actions which may reduce sediment runoff in Third Fork Creek. For example, planting a vegetated buffer, stabilizing a gravel driveway, or growing a healthy lawn can reduce sediment and erosion issues on private property. The Public Works' Stormwater Quality and Watershed Planning groups will leverage previous public education and outreach efforts to inform residents about sources, pollution prevention techniques, transport pathways, and impacts of sediment on local streams. ■ Implement an Adopt -a -Drain program that encourages residents to participate in removing sediment, leaves, and trash from the street gutter near and around storm drain grates. An interactive web map and registration website have been developed for this program. Public education staff in the Public Works' Watershed Planning Group will be responsible for managing the Adopt -a -Drain program when it is handed over to the City in 2019. Increase street sweeping frequency in the Third Fork Creek watershed. The Public Works Operations Division will aim to increase the annual number of streets swept in Third Fork Creek. To date, the amount of street sweeping has been limited by the staffing numbers in the division. The Operations Division will aim to increase the number of street maintenance staff members. Challenges to successfully implementing this measure include identifying qualified candidates and retaining staff members. Purchase, supply, and educate Public Works Operations Division field staff with the materials they need to protect storm drains during street maintenance work. The Public Works Department will purchase supplies for street maintenance crews to protect storm drains during street maintenance operations. The pollution prevention supplies will be distributed to and utilized within the Public Works Operations Division. The Stormwater Quality group's pollution prevention staff will assist in providing training to street maintenance crews. Review the Third Fork Creek Watershed Improvement Plan (WIP) and implement the construction of SCMs identified in the WIP that address TSS. The City's Watershed Planning Group and Stormwater Quality Group will be responsible for reviewing the WIP and prioritizing SCMs that will be built, assuming available land, funding, and public support. The Watershed Planning Group will be responsible for coordinating public communication, land acquisition, and contract management for the construction of the SCMs. Explore strategies to promote greater use of green infrastructure to complement traditional SCMs & BMPs in the City's post -construction stormwater management efforts. This includes determining effective incentives to encourage green infrastructure utilization on private site development. Investigate using green infrastructure on City projects. Research and recommend effective City code changes to reduce barriers to implementing green infrastructure in public and private development projects. (A) For development and planning, designate slopes as Preserved (natural areas >25 % slope) and Man-made (managed areas >25%). (B) Eliminate 50% slope (2:1) allowance. Add steep slope violation, encroachment clarification in the Unified Development Ordinance. The City -County Planning Department will investigate the development of slope protection regulations for natural areas and managed areas, eliminate 50% slope (2:1) allowance, and clarify steep slope encroachment violation language in the ordinance. This will include modification of existing slope protection rules and/or development of new rules. The Planning Department will lead the modification of the Unified Development Ordinance and the approval process through the City : TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Council. The Public Works' Stormwater Development Review Group and Engineering Services Division will assist in the ordinance change. 19 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Table 3. Prioritized Measures in the Third Fork Creek watershed Proposed Measure Type of NPDES Minimum Measure Estimated Impact on Reducing Group(s) Responsible for Measure Estimated Cost Implementation Measure Turbidity/TSS Implementation to Implement Timeline (years) Measure Perform additional streambank stabilization and restoration. Mitigation NA High Public Works - Watershed Planning; Public $$$ 10-15 Works - Infrastructure; County Soil & Water Conservation District Increase street sweeping frequency in the Third Fork Creek watershed. Mitigation Pollution Prevention/Good High Public Works - Operations $$$ 5-15 Housekeeping for Municipal Operations More frequent sediment & erosion inspections and enforcement. Mitigation Construction Site Stormwater Runoff High County Stormwater & Erosion Control 5-15 Control Promote the use of flocculants in drainage ditches on construction Mitigation Construction Site Stormwater Runoff High Public Works - Stormwater & GIS - IDDE; $ 0-5 sites to settle out sediment and solids. Create a one -page handout Control County Stormwater and Erosion Control about flocculant guidance or update current construction handout to include guidance on the use of flocculants. Review Third Fork Watershed Improvement Plan (WIP) and implement Mitigation NA Medium -High Public Works - -Watershed Planning and $$$ 5-10 the construction of SCMs identified in the WIP that address TSS. Stormwater Quality Routine stream -walk program to target the main stem and tributaries Mitigation Illicit Discharge Detection and Medium Public Works - Stormwater Quality 0-5 with historically higher incidences of illicit discharges. Also, inspect Elimination and assess stream bank erosion. Investigate highly effective channel protection methods to reduce Mitigation Post -Construction Stormwater Medium Public Works - Stormwater Development $ 0-5 streambank scour including stream channel protection volume (CPV) Management Review measures. Explore strategies to promote greater use of green infrastructure to Mitigation Post -Construction Stormwater Low -Medium Public Works - Stormwater Development 5-10 complement traditional SCMs & BMPs in the City's post -construction Management Review stormwater management efforts. Change City code to grant authority for the City's Public Works Mitigation Construction Site Stormwater Runoff Low -Medium Public Works - Stormwater Quality; City $ 5-10 Department to issue a "stop -work order" for small construction sites Control Attorney; City Manager; City Council that are not in compliance with required sediment and erosion control practices. Purchase and supply Public Works Operations Division field staff with Prevention Pollution Prevention/Good Low -Medium Public Works - Operations $ 0-5 the materials they need to protect storm drains during maintenance Housekeeping for Municipal Operations work in the street. Conduct a media campaign to motivate the public to take specific Prevention Public Education and Outreach Low -Medium Public Works - Stormwater Quality and $ 0-5 actions that reduce sources of sediment and turbidity through the Watershed Planning; CWEP Contractor City's website, online videos (e.g. YouTube), social media accounts, Waterways newsletter, CWEP handouts, and other methods. (A) For development and planning, designate slopes as Preserved Prevention Construction Site Stormwater Runoff Low -Medium [(A) - Low, (B) - Med)] Public Works -Stormwater Development $ - $$ 5-10 (natural areas >25% slope) and Man-made (managed areas >25%). Control Review and Engineering Services; City- (B) Eliminate 50% slope (2:1) allowance. Steep slope violation, County Planning; encroachment clarification in the Unified Development Ordinance. Implement an Adopt -a -Drain program that encourages residents to Prevention Public Participation and Involvement Low Public Works - Watershed Planning $ 0-5 participate in removing sediment, leaves, and trash from the street gutter near and around storm drain grates. Estimated Costs: $$$ > $500,000, = $50,000 to $500,000, $ <$50,000. Estimated costs consider only the projected costs to the City and County departments. 20 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 8. Prioritized Measures Applicable to the NPDES Six Minimum Measures This section highlights the prioritized response plan measures that fall under the six minimum control measures for the EPA's Stormwater Phase II Final Rule. The prioritized measures in this response plan address Public Education and Outreach, Public Participation and Involvement, IDDE, Construction Site Stormwater Runoff Control, and Post -Construction Stormwater Management, Pollution Prevention and Good Housekeeping 8.1. Implementation of Plan to the Maximum Extent Practicable The City will implement response plan measures to the maximum extent practicable (MEP) with the goal of reducing the levels of turbidity and TSS in Third Fork Creek. While the elimination of all turbidity and TSS point and nonpoint sources may reduce concentrations below water quality standards, it is recognized that this may not be feasible due to technical, economic, logistic or social factors. Therefore, the City will pursue turbidity and TSS reductions to the MEP based on Clean Water Act and MS4 NPDES requirements. Section 402(p)(3)(B) of the Clean Water Act requires municipal MS4 permittees, to the extent allowable under State or local law, to prohibit non-stormwater discharges into the MS4 and implement controls and management measures to reduce the discharge of pollutants to the maximum extent practicable. Section J(1)(b) of the City's MS4 NPDES permit also requires that the City utilize BMPs (commonly referred to as SCMs) pertaining to the six minimum measures and the TMDL Response Plan to meet the approved TMDL WLA to the MEP. Additionally, Section J(1)(c) of the City's MS4 NPDES also states that the City is not responsible for attaining State water quality standards as this requires pollutant reductions from all point and nonpoint sources identified in the approved TMDL. 8.2. Public Education and Outreach City of Durham, Public Works Department, Stormwater & GIS Services Division Measure Timeline ■ Conduct a media campaign to motivate the public to take 0 to 5 years specific actions that reduce sources of sediment and turbidity through the City's website, online videos (e.g. YouTube), social media accounts, Waterways newsletter, CWEP handouts, and other methods. 8.3. Public Participation and Involvement City of Durham, Public Works Department, Stormwater & GIS Services Division Measure Timeline Implement an Adopt -a -Drain program that encourages 0 to 5 years residents to participate in removing sediment, leaves, and trash from the street gutter near and around storm drain grates. 21 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 8.4. Illicit Discharge Detection and Elimination City of Durham, Public Works Department, Stormwater & GIS Services Division Measure Timeline ■ Routine stream -walk program to target main stem and 0 to 5 years tributaries with historically higher incidences of illicit discharges of sediment. Also inspect major outfalls (greater than 36" diameter pipe) for turbid discharges and assess stream bank erosion. 8.5. Construction Site Stormwater Runoff Control City of Durham, Public Works Department, Stormwater & GIS Services Division Measure ■ Promote the use flocculants in drainage ditches on construction sites to settle out sediment and solids. Create a one -page handout about flocculant guidance or update current construction handout to include guidance on the use of flocculants. ■ Change City code to grant the Public Works Department authority to issue a "stop work order" for small construction sites that are not in compliance with required sediment and erosion control practices. Timeline 0 to 5 years 5 to 10 years Durham County, Engineering and Environmental Services Department, Stormwater and Erosion Control Division Measure Timeline ■ Conduct more frequent sediment & erosion inspections and 5 to 15 years enforcement. 22 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 8.6. Post -Construction Stormwater Management of Durham, Public Works Department, Stormwater & GIS Services Division Measure Timeline ■ Investigate highly effective channel protection methods to 0 to 5 years reduce streambank scour including stream channel protection volume (CPV) measures. ■ Explore strategies to promote greater use of green 5 to 10 years infrastructure to complement traditional SCMs & BMPs in the City's post -construction stormwater management efforts. 8.7. Pollution Prevention/Good Housekeeping for Municipal Operations City of Durham, Public Works Department, Operations Division Measure ■ Purchase and supply Public Works Operations Division field staff with the materials they need to protect storm drains during maintenance work in the street. Increase street sweeping frequency in the Third Fork Creek watershed. 9. Watershed Planning Timeline 0 to 5 years 5 to 15 years Watershed planning is an additional measure that the City of Durham has incorporated into the Stormwater program. Although this is not one of the Phase II minimum measures, this program does provide information and direction regarding practices in the Third Fork Creek watershed. In 2007 the City began the process of developing Watershed Improvement Plans for watersheds across the City. As of December 2018, watershed improvement plans have been completed for Ellerbe Creek, Northeast Creek, Crooked Creek, Third Fork Creek, Little Lick Creek, and Eno River. Each plan identifies new opportunities for stormwater control measures, as well as opportunities to upgrade existing measures (i.e., retrofit existing measures). Extensive field work is conducted in the watershed planning process to verify on - the -ground conditions prior to carrying a project concept forward. Stream restorations are also evaluated as potential control measures to pollution that can arise from the stream bank (e.g., sediment/turbidity). Each plan provides a recommended list of ranked new stormwater control measures, opportunities for retrofitting measures, and stream restoration. Cost estimates are provided for each measure or restoration opportunity. The City finalized the Third Fork Creek Watershed Improvement Plan in December 2012. The Watershed Improvement Plan notes that approximately 23 percent of the Third Fork Creek watershed lies within the 23 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 watershed protection overlay district. New development has been required to design stormwater controls to remove 85 percent of total suspended solids within the watershed overlay district since 1985, and everywhere in Third Fork Creek since 2009 when Phase II post -construction requirements took effect. The Third Fork Creek Watershed Improvement Plan found that 35% of the channels within Third Fork Creek were rated as Fair and 19% were rated as poor for channel stability. The completed plan recommended stream corridor restoration for six stream reaches, or 5,475 feet of stream. Stream corridor restoration would have a high impact on sediment levels in Third Fork Creek and these reaches have been identified as unstable or degraded to the point where they are significantly contributing to water quality problems as discussed in section 2.4.6 of the Stormwater Management Plan. A computer -based watershed water quality model known as the Storm Water Management Model (SWMM) was set up to simulate the Third Fork Creek watershed and help develop the WIP. The model simulated the capability of existing SCMs in the watershed to manage runoff volume and pollutant washoff (including sediment). The model helped identify areas with the highest amounts of pollutants of concern and prioritize areas in need of new or improved stormwater treatment. There were numerous recommendations for new SCMs or SCM retrofits that included constructed wetlands, bioretention areas, and wet detention ponds. Each of these types of structural SCMs also remove sediment, including the smallest particles that cause turbidity. Structural SCMs also provide peak flow detention of stormwater runoff from impervious surfaces and helps reduce the presence of erosive high -flow conditions in stream channels. A total of 15 new high - priority structural SCMs were recommended in the Third Fork Creek WIP. 10. Water Quality Assessment and Monitoring 10.1. Water Quality Monitoring The City of Durham has a routine ambient stream monitoring program to generate data that describe the condition of streams in the City and County limits. The City's Stormwater Management Plan states that the ambient stream monitoring program supports the following assessment goals (City of Durham, 2017): ■ to identify pollution problem areas within the City of Durham; ■ to assess compliance with state water quality programs, including TMDLs and nutrient management strategies; ■ to determine pollution removal credits; ■ to identify overall water quality trends; and ■ to evaluate the water quality impacts of urban stormwater on area streams The monitoring program includes water chemistry, biological monitoring (benthic macroinvertebrates and habitat assessment), and hydrologic monitoring. The ambient water chemistry program focuses on surface water conditions. Special studies are conducted on an infrequent basis to assess stream sediment chemistry. City monitoring staff follow procedures outlined in the Ambient Water Chemistry Monitoring Program Quality Assurance Project Plan and collect grab samples monthly at scheduled monitoring sites. Samples are collected at all monitoring sites in a given basin on the same day. The City uses a rotating stream basin approach to monitor sites in each basin every two years; however, monitoring sites are evaluated at the end of each year and site locations are adjusted to meet the City's water quality assessment needs. The TMDL for Third Fork Creek was developed because turbidity violations were the reason for listing the creek on the state 303(d) list; however, the TMDL is expressed in terms of TSS loading. The TMDL assumes that in meeting the TSS target load that the turbidity violations will decrease to an acceptable level. The City of Durham tracks both turbidity and TSS loads in Third Fork Creek in order to evaluate compliance with both the TMDL and the water quality standard for turbidity. 24 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 The Third Fork Creek ambient stream monitoring sites for the City, Upper Cape Fear River Basin (UCFRBA), and State Division of Water Resources (DWR) are shown below in Figure 4. The City of Durham has seven water quality monitoring stations in Third Fork Creek - five stations are monitored on even years and two locations are monitored consistently that are near continuous stream monitoring gaging stations. These two locations (TF3.4.TC and TFLOTC) are near the Public Works Operation Center at MLK Jr. Pkwy and further downstream at Woodcroft Pkwy. Downstream of these City of Durham monitoring stations is the UCFRBA monitoring station at Highway 54 (133025000) and continuous discharge data collection by the US Geological Survey. This location is the TMDL compliance point. The acceptable criterion at the compliance point is no more than 10% of the turbidity data in a five-year period exceeding the water quality standard of 50 NTU. Evaluating turbidity on an annual basis since 2010, turbidity levels have exceeded the water quality standard in more than 10% of samples during three years. In September 2018, a completed stream restoration project stabilized 1,250 linear feet of Third Fork Creek and replaced 700 linear feet of an asphalt walking trail with a new boardwalk. This may affect turbidity concentrations as well as annual loads. 25 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 0 Owham -N� #IeCreek i Headwaters New Hope ancfy i Creek Creek TF4 4T SIrTF5-3RC FF5-iRC �-' Third t TF3.4TC, c>rk reek, F 7. TCTC , TF2.4 - r TF OTC 130 49830250N Ko r-. '1+ 6V Hope Creek New Hope Little trreek•S Everett _ Jordan Lake y Northeast Creek f thiM Fa-rk creek Walmmh ed Wak! N ■ war rwya*a 4'�eo-an+dc • our �Mo spa Cr, -imn CITY OF R ems, 0 0 1 2 DURHAM aTr hfi s Figure 4. City of Durham, UCFRBA, and DWR ambient stream monitoring sites in the Third Fork Creek watershed. 26 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 10.2. Turbidity Data and Computed TSS Loads Loads of TSS are typically calculated annually using the USGS load estimation program LOADEST (Mod4.8, March 2013). For each NPDES Permit Annual Report Update, loads are recalculated each year. A minimum of 5 years of data are used to calibrate LOADEST for TSS load calculations. As a result, all load estimations in this report will differ from previous reports, in some years significantly. Estimates of the mean monthly load are provided by LOADEST, including the upper and lower 95% confidence limits on the mean monthly load. These were used to estimate the mean annual load and the 95% confidence limits on that load. These load estimates were compared to the TMDL load of 547,500 pounds/year. 11. Water Quality Co -Benefits of TMDL Response Plan Implementation Implementation of the priority measures for the Third Fork Creek TMDL Response Plan aims to reduce turbidity and TSS loading to the creek and will also have co -benefits in reducing other pollutants and improving the aquatic habitat. For example, reduction of sediment in Third Fork Creek could reduce other pollutants like metals and nutrients. Reductions of these pollutants, possible increases in dissolved oxygen concentrations, and improved aquatic habitat quality could lead to healthier populations of benthic macroinvertebrates and fish. 11.1. Value Added to Removal of Nutrients and Metals A co -benefit of implementing priority measures with this TMDL Response Plan is decreased transport of nutrients and other pollutants. Instream concentrations of heavy metals like copper, zinc, and lead have been correlated with higher suspended sediments and are transported during storm events (Balogh et al., 1997; Cravotta and Bilger,2001). Reduced TSS loading achieved through the implementation of priority measures could result in lower concentrations of copper, which is a pollutant that Third Fork Creek is listed for on the Final 2016 NCDEQ 303d list (NCDEQ, 2016; Table 4). Suspended sediment can also serve as a transport medium for nutrient pollutants like nitrogen and phosphorus (House et al., 1998). Reductions in nutrient loading achieved could positively impact water quality in Jordan Lake, which, is currently impacted by excess nutrients. Suspended sediment is comprised of a mixture of flocculated inorganic particles (e.g., clays and silts), bacterial and algal communities, and organic particles (Droppo, 2001) - decreasing suspended sediment loading could lead to decreased bacteria transport (Badgley et al., 2011). Decreased turbidity and TSS would increase water clarity and light penetration into the water column, fostering the growth of plants and algae at the primary trophic level (Henley et al., 2000). This could increase dissolved oxygen generation through photosynthetic activity, helping address the 2016 Final 303(d) listing of Third Fork Creek for dissolved oxygen. Table 4. NCDEQ 2016 Final 303(d) List (NCDEQ 2016), Category 5 Assessments for Third Fork Creek. Impaired Description of Assessment segment Assessment Reason for Rating Parameter of I Category stream segment Unit(s) length Criteria Status Interest (miles) From source to a 16-41-1-12- 5.16 Exceeding > 10% and >90% conf Zinc (50 pg/L;) 5 point 2.0 miles (1) Criteria > 10% and <90% conf Copper (7 ug/L) 5e upstream of NC > 10% and >90% conf Dissolved Oxygen (4 5 Hwy. 54 mg/L) From a point 2.0 16-41-1-12- 3.86 Exceeding > 10% and >90% conf Dissolved Oxygen (4 5 miles upstream of (2) Criteria mg/L;) NC HWY. 54 to New > 10% and <90% conf Copper (7 ug/L) 5e Hope Creek 27 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 11.2. Benefits to Aquatic Life Reducing turbidity and TSS could potentially foster significant improvements in fish, benthic macroinvertebrates, and aquatic life in Third Fork Creek. Fine fractions of suspended sediment are known to result in declines in benthic macroinvertebrates and fish presence and diversity (Henley et al., 2000; Bilotta and Brazier, 2008) - implementation of priority measures for this TMDL Response Plan could potentially result in increased health in populations of these aquatic insects. The growth of plants and algae at the primary trophic level, discussed above, could create a healthier habit for benthic macroinvertebrates and fish to thrive. Decreased suspended sediment concentrations have been shown to decrease microbial production of ammonia, which is toxic to fish (Xia et al., 2009). 12. Steps Towards TMDL Response Plan Implementation The Third Fork Creek TMDL Response Plan will be implemented by workgroups in Durham City and County government. This implementation process is not necessarily a direct prescriptive process - depending on the level of change that implemented response measures are having on turbidity and TSS loads in Third Fork Creek. Adapting and modifying the response plan will be informed through ongoing analysis of programmatic data collected to quantify progress. 12.1. Response Plan Schedule by Agency This section organizes the prioritized response plan measures by the departments that are responsible to implement them. The prioritized measures in this response plan will be implemented in partnership between City of Durham Public Works Department (Stormwater and GIS Services Division, Operations Division) and Durham County, Engineering and Environmental Services Department, Stormwater and Erosion Control Division. The timeline for implementation of the prioritized response plan measures is between five and fifteen years. TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 City of Durham, Public Works Department, Stormwater & GIS Services Division Measure Timeline ■ Conduct a media campaign to motivate the public to take 0 to 5 years specific actions that reduce sources of sediment and turbidity through the City's website, online videos (e.g. YouTube), social media accounts, Waterways newsletter, CWEP handouts, and other methods. ■ Implement an Adopt -a -Drain program that encourages 0 to 5 years residents to participate in removing sediment, leaves, and trash from the street gutter near and around storm drain grates. ■ Routine stream -walk program to target main stem and 0 to 5 years tributaries with historically higher incidences of illicit discharges. Also inspect and assess stream bank erosion. ■ Promote the use of flocculants in drainage ditches on 0 to 5 years construction sites to settle out sediment and solids. Create a (in coordination with one -page handout about flocculant guidance or update current County Stormwater & construction handout to include guidance on the use of Erosion Control Div.) flocculants. ■ Investigate highly effective channel protection methods to 0 to 5 years reduce streambank scour including stream channel protection volume (CPV) measures. ■ Explore strategies to promote greater use of green 5 to 10 years infrastructure to complement traditional SCMs & BMPs in the City's post -construction stormwater management efforts. ■ Review Third Fork Watershed Improvement Plan (WIP) and 5 to 10 years implement the construction of SCMs identified in the WIP that address TSS. ■ Change City code to grant authority for the City's Public Works 5 to 10 years Department to issue a "stop work order" for small construction (in coordination with City sites that are not in compliance with required sediment and Management and Council) erosion control practices. ■ (A) For development and planning, designate slopes as 5 to 10 years Preserved (natural areas >25% slope) and Man-made (in coordination with Eng. (managed areas >25%). (B) Eliminate 50% slope (2:1) Services Div. and City - allowance. Steep slope violation, encroachment clarification in County Planning Dept.) ordinance. ■ Perform additional streambank stabilization and restoration. 10 to 15 years 29 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 City of Durham, Public Works Department, Operations Division Measure Purchase and supply Public Works Operations Division field staff with the materials they need to protect storm drains during maintenance work in the street. ■ Increase street sweeping frequency in the Third Fork Creek watershed. Timeline 0 to 5 years 5 to 15 years Durham County, Engineering and Environmental Services Department, Stormwater and Erosion Control Division Measure Timeline ■ Conduct more frequent sediment & erosion inspections and 5 to 15 years enforcement. 12.2. Tracking and Data Collection The City's Public Works Department will communicate with the appropriate departments, divisions, and workgroups to identify the metrics and data needed to track the progress of measures outlined in this Response Plan. A preliminary list of metrics that may be used to track incremental progress for this Response Plan is shown in Appendix C. 12.3. Re-evaluation of Response Plan The City's Public Works Department will re-evaluate the measures outlined in this TMDL Response Plan on a five-year basis, as resources allow. Modifications to the response plan will depend on reductions in turbidity and TSS concentrations, the feasibility of implementing measures, stakeholder needs, and new measures identified. The City will continue to provide progress updates on an annual basis as part of the NPDES Municipal Stormwater Permit annual reporting cycle. 13. References Allmendinger, N.E., Pizzuto, J. E., Moglen, G. E., and Lewicki, M. 2007. A sediment budget for an urbanizing watershed 1951-1996, Montgomery County, Maryland, U.S.A. Journal of the American Water Resources Association, 43(6), 1483-1498. Badgley, B. D., Thomas, F. I. M. and Harwood, V. J. 2011. Quantifying environmental reservoirs of fecal indicator bacteria associated with sediment and submerged aquatic vegetation. Environmental Microbiology 13(4), 932-942. 30 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Bilotta, G. S. and Brazier, R. E. 2008. Understanding the influence of suspended solids on water quality and aquatic biota. Water Research 42(12), 2849-2861. City of Durham. 2017. City of Durham Stormwater Management Program Plan. Public Works Department. August, 2017. Durham, NC. Droppo, I. G. 2001. Rethinking what constitutes suspended sediment. Hydrological Processes 15(9), 1551- 1564. Henley, W. F., Patterson, M. A., Neves, R. J. and Lemly, A. D. 2000. Effects of sedimentation and turbidity on lotic food webs: A concise review for natural resource managers. Reviews in Fisheries Science 8(2), 125- 139. House, W. A., Jickells, T. D., Edwards, A. C., Praska, K. E. and Denison, F. H. 1998. Reactions of phosphorus with sediments in fresh and marine waters. Soil Use and Management 14, 139-146. Nelson, P.A., Smith, J.A., and Miller, A.J. 2006. Evolution of channel morphology and hydrologic response in an urbanizing drainage basin. Earth Surf. Process. Landf. 31, 1063-1079. North Carolina Department of Environment and Natural Resources (NCDENR). 2003. North Carolina Water Quality Assessment and Impaired Waters List (2002 Integrated 305(b) and 303(d) Report). February, 2003. Raleigh, NC. North Carolina Department of Environment and Natural Resources (NCDENR). 2005. Total Maximum Daily Load for Turbidity and Fecal Coliform for Haw River, Deep River, Third Fork Creek, and Dan River in North Carolina. January, 2005. Raleigh, NC. North Carolina Department of Environmental Quality (NCDEQ). 2016. 2016 Integrated Report - All Assessed Waters, 2016 Final 303(d) List. April, 2018. Raleigh, NC. 0' Driscoll, M., Clinton, S., Jefferson, A., Manda, A., and McMillan, S. 2010. Urbanization Effects on Watershed Hydrology and In -Stream Processes in the Southern United States. Water 2, pg. 605-648. Tetra Tech. 2012. Durham Third Fork Creek Watershed Management Plan. Prepared for the City of Durham. December, 2002. Durham, NC. U.S. Environmental Protection Agency (USEPA). 1991. Guidance for Water Quality -based Decisions: The TMDL Process. Assessment and Watershed Protection Division. April, 1991. Washington, DC. Waite, T.D. 1984. Principles of Water Quality. Academic Press, New York. Xia, X., Yang, Z. and Zhang, X. 2009. Effect of suspended -sediment concentration on nitrification in river water: Importance of suspended sediment -water interface. Environmental Science and Technology 43(10), 3681-3687. 31 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 14. Appendix A: Summary Table of All Proposed Measures (Priority and Non -Priority) Table 5 Priority and non -priority measures proposed for the Third Fork Creek TMDL Response Plan Proposed Measure Type of NPDES Minimum Measure Estimated Impact Group(s) Responsible for Measure Estimated Implementation Priority Measure on Reducing Implementation Cost to Timeline Turbidity/TSS Implement (years) Measure Perform additional streambank stabilization and restoration. Mitigation NA High Public Works -Watershed Planning; $$$ 10-15 Yes Public Works - Infrastructure; Soil & Water Conservation District Increase street sweeping frequency in the City. Mitigation Pollution Prevention/Good Housekeeping High Public Works - Operations - $$$ 5-15 Yes for Municipal Operations More frequent sediment & erosion inspections and enforcement. Mitigation Construction Site Stormwater Runoff Control High County Stormwater and Erosion Control 5-15 Yes Promote the use of flocculants in drainage ditches on construction Mitigation Construction Site Stormwater Runoff Control High Public Works - Stormwater Quality; $ 0-5 Yes sites to settle out sediment and solids. Create a one -page handout County Stormwater and Erosion Control about flocculant guidance or update current construction handout to include guidance on the use of flocculants. Review Third Fork Watershed Improvement Plan (WIP) and implement Mitigation NA Medium -High Public Works - Watershed Planning and $$$ 5-10 Yes the construction of SCMs identified in the WI that address TSS. Stormwater Quality Routine stream -walk program to target the main stem and tributaries Mitigation Illicit Discharge Detection and Elimination Medium Public Works - Stormwater -Quality $$ 0-5 Yes with historically higher incidences of illicit discharges. Also, inspect and assess stream bank erosion. Investigate highly effective channel protection methods to reduce Mitigation Post -Construction Stormwater Management Medium Public Works - Stormwater Development $ 0-5 Yes streambank scour including stream channel protection volume (CPV) Review measures. Explore strategies to promote greater use of green infrastructure to Mitigation Post -Construction Stormwater Management Low -Medium Public Works - Stormwater Development $$ - $$$ 5-10 Yes complement traditional SCMs & BMPs in the City's post -construction Review stormwater management efforts. Change City code to grant authority for the City's Public Works Mitigation Construction Site Stormwater Runoff Control Low -Medium Public Works - Stormwater Quality; City $ 5-10 Yes Department to issue a "stop -work order" for small construction sites Attorney; City Manager; City Council that are not in compliance with required sediment and erosion control practices. Purchase and supply Public Works Operations Division field staff with Prevention Pollution Prevention/Good Housekeeping Low -Medium Public Works - Operations $ 0-5 Yes the materials they need to protect storm drains during maintenance for Municipal Operations work in the street. Conduct a media campaign to motivate the public to take specific Prevention Public Education and Outreach Low -Medium Public Works - Watershed Planning and $ 0-5 Yes actions that reduce sources of sediment and turbidity through the Stormwater Quality; CWEP Contractor City's website, online videos (e.g. YouTube), social media accounts, Waterways newsletter, CWEP handouts, and other methods. 32 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Table 5 Priority and non -priority measures proposed for the Third Fork Creek TMDL Response Plan Proposed Measure Type of NPDES Minimum Measure Estimated Impact Group(s) Responsible for Measure Estimated Implementation Priority Measure on Reducing Implementation Cost to Timeline Turbidity/TSS Implement (years) Measure (A) For development and planning, designate slopes as Preserved Prevention Construction Site Stormwater Runoff Control Low -Medium [(A) - Public Works -Stormwater Development 5-10 Yes (natural areas >25% slope) and Man-made (managed areas >25%). Low, (B) - Med)] Review and Engineering Services; City- (B) Remove 50% slope (2:1) allowance and add steep slope violation, County Planning; encroachment clarification in the Unified Development Ordinance. Implement an Adopt -a -Drain program that encourages residents to Prevention Public Participation and Involvement Low Public Works - Watershed Planning 0-5 Yes participate in removing sediment, leaves, and trash from the street gutter near and around storm drain grates. Promote stream buffer education for residents that disturb land or Prevention Public Education and Outreach Low -Medium City -County Planning, Public Works- $ 0-5 No perform construction work on their property. Watershed Planning, County Stormwater and Erosion Control, Soil & Water Conservation District, City- County Inspections (A) Provide incentives to attend public education events for invasive Prevention Public Education and Outreach Low Public Works - Watershed Planning and $ 0-5 No species education, such as partnering with local nurseries to give out Infrastructure, Soil & Water native plants. (B) Conduct public outreach on ways to improve Conservation District residential buffers. Expand "no mow zones" pilot program with Water Management and Prevention NA Low Water Management, Public Works - $ 5-10 No explore other potential "no mow" areas and partners. Watershed Planning Require sediment & erosion control practices for critical areas on Prevention Construction Site Stormwater Runoff Control Low City -County Planning, County Stormwater $ 0-5 No construction sites that are directly adjacent to buffers. & Erosion Control Improve concrete cutting and installation practices for Public Works Prevention Pollution Prevention/Good Housekeeping Low Public Works Operations, Stormwater $ 0-5 No Operations projects (managing concrete slurry and washout controls). for Municipal Operations Quality Advertise the Muddy Water Watch App on websites, social media, and Prevention Public Education and Outreach Low County Stormwater and Erosion Control $ 0-5 No at public events. Develop partnerships with outside organizations to acquire or secure Prevention NA Low -Medium Public Works - Watershed Planning $$$ 10-15 No easements in riparian areas where a native vegetated buffer can be protected or restored. Conduct street sweeping in residential areas with cul-de-sacs that Mitigation Pollution Prevention/Good Housekeeping Low Public Works - Operations $ 0-5 No have stormwater outfalls near a stream. Develop routes using GIS for Municipal Operations maps. Use aerial photography to identify denuded areas or Mitigation Illicit Discharge Detection and Elimination Low Public Works - Stormwater Quality $ 0-5 No sites with sediment and erosion issues. Mitigate flow from older DOT roads by installing retrofits on DOT Mitigation NA Medium NCDOT $$$ 10-15 No easements. Educate road designers about better stormwater control practices. Prevention Public Education and Outreach Low City Transportation Department $ 5-10 No 33 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 Table 5 Priority and non -priority measures proposed for the Third Fork Creek TMDL Response Plan Proposed Measure Type of NPDES Minimum Measure Estimated Impact Group(s) Responsible for Measure Estimated Implementation Priority Measure on Reducing Implementation Cost to Timeline Turbidity/TSS Implement (years) Measure Evaluate the feasibility of a program to identify barren or unvegetated Mitigation NA Low Public Works -Watershed Planning 5-10 No land where native plants may be established using simple techniques such as seeding, planting, and live staking. Targeted stormwater outfall program in both watersheds. Check Mitigation Illicit Discharge Detection and Elimination Low Public Works - Stormwater Quality 0-5 No selected hot spot (<15) outfalls annually. Outfalls where previous contamination issues have been observed are considered `hot spots'. Targeted investigations and stream survey. Quickly assess field Mitigation Illicit Discharge Detection and Elimination Low Public Works - Stormwater Quality 0-5 No conditions and identify illicit discharges in priority catchments. Inspect outfalls, business corridors, and apartment complexes during baseflow conditions. Implement a pilot program with existing staff to conduct proactive investigations during the weekdays. Query information from sanitary sewer inspection reports on Mitigation Illicit Discharge Detection and Elimination Low Public Works - Stormwater Quality $ 0-5 No CityWorks using keywords for sediment issues (failing stream banks, private and public sewer spills, etc.) for Stormwater Services to investigate and report back to City Works users for tagging feedback. Zoning Enforcement and Water Quality Investigator cross -training; Mitigation Illicit Discharge Detection and Elimination Low Public Works - Stormwater Quality; City- $ 0-5 No enhancing communication between departments based on better County Planning understanding of each other's requirements but does not include the authority to enforce each other's code. Raise more awareness on preventing sediment from reaching creeks Prevention Public Education and Outreach Low Public Works - Stormwater Quality, $ 0-5 No and storm drains. Target outreach efforts towards homeowners and Watershed Planning landscaping businesses. Provide sediment control materials for stormwater roadside ditch Prevention Pollution Prevention/Good Housekeeping Low - Medium Public Works - Operations $ 0-5 No work and install controls prior to ditch work. These sediment controls for Municipal Operations will be used for projects occurring longer than 1 day. Estimated Costs: $$$ > $500,000, = $50,000 to $500,000, $ <$50,000. Estimated costs consider only the projected costs to the City and County departments. 34 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 15. Appendix B: Summary Table of Measures Not Included in the TMDL Response Plan Table 6. Measures considered and not currently feasible for implementation in the Third Fork Creek TMDL Response Plan Proposed Measure Type of Measure NPDES Minimum Estimated Impact on Group(s) Responsible for Measure Estimated Cost to Implementation Measure Reducing Turbidity/TSS Implementation Implement Measure Timeline (years) Conduct more enforcement of stream buffer rules in the Unified Mitigation NA Low -Medium City -County Planning 0-5 Development Ordinance. Raise more awareness on reporting sediment discharges in creeks and Prevention Public Education and Low Public Works - Stormwater Quality, 0-5 storm drains by using an anonymous reporting app. [This idea overlaps with Outreach County Stormwater & Erosion Muddy Water Watch App used by County Stormwater & Erosion Control] Control Consider requiring an S&E plan that developers submit with a small site plan Prevention Construction Site Low -Medium City -County Planning 5-10 along with a security deposit, or submit S&E plan and have 'sign if icant'fines Stormwater Runoff if developers do not implement S&E practices. Control Expand "Let It Grow" program - help stabilize stream banks by planting Prevention Public Education and Low Watershed Planning 0-5 native grasses along City -owned easements and creeks. Outreach Require limit on the area of mass grading for construction sites. Require a Prevention Construction Site Medium -High City -County Planning 10-15 phased approach for clearing and grading on construction sites Stormwater Runoff Control Build partnerships with nurseries and other garden stores to set up Prevention Public Education and Low Public Works - Stormwater Quality $ 0-5 education kiosks and incentives. Outreach Place signs along trails (near creeks and sewer lines) to raise public Prevention Public Education and Low Trail Advisory Group $ 0-5 awareness on how and what to report (regarding cloudy water, turbidity, Outreach sediment) for sediment discharges. Provide weekend answering service for Stormwater Pollution Hotline (560- Mitigation Illicit Discharge Low -Medium Public Works - Stormwater Quality 0-5 SWIM) or designate on -call staff members. Detection and Elimination Install infiltration/biofilter swales along roadside ditches to reduce sediment Mitigation NA Medium NCDOT; Public Works - Operations $$$ 10-15 and erosion. *Estimated Costs: $$$ > $500,000, = $50,000 to $500,000, $ <$50,000. Estimated costs consider only the projected costs to the City and County departments. 35 TMDL Response Plan for Turbidity in Third Fork Creek, Durham, NC March 19, 2019 16. Appendix C: Measure of Incremental Progress Implementation of any one measure may not directly impact turbidity levels or TSS concentrations in Third Fork Creek. Implementing a combination of measures may reduce sediment levels to a much greater extent. The following table lists the incremental progress that will be tracked for this TMDL Response Plan. This tracking is in addition to any tracking performed through the monitoring program. Table 7 Preliminary list of incremental progress TMDL Response Plan Metric Metric Reporting Reporting Frequency In -Stream Sediment Sources Linear feet of stream restored and bank stabilized Linear feet Every five years Construction/Development Source of Sediment Number of storm drain protection kits purchased Count Annually and provided to Public Works Operations Division Number of "stop -work orders" issued for non- Count Annually compliant construction sites Number of Sediment & Erosion Control inspections Count Annually conducted Runoff from Impervious Surfaces and Direct Dischar>?e Number of curb miles of streets swept Miles Annually Number of construction plans approved with green Count Every five years infrastructure practices Number of SCMs from WIP installed Count Every five years Linear feet of streams walked in the Third Fork Linear feet Annually Creek watershed Educational Material Tracking Number of flocculent -education handouts Count Annually distributed to residents and businesses Number of social media informational Count Annually advertisements published Public Participation Tracking Number of storm drains adopted by residents Count Annually 36