HomeMy WebLinkAboutNCS000250_NCDOTs Permit Changes Summary_20220617NPDES Permit NCS000250
Summary of Notable Changes from Term IV to Term V (effective May 1, 2022)
AHM/srm
June 17, 2022
Permit Coverage - largely remained unchanged with the notable exception that the Global TransPark is now fully under
this permit.
Permit Format - major format changes to make the permit more consistent in format with other MS4(Municipal
Separate Storm Sewer System) permits in the state. The permit also requires the preparation of a TS4SMP which
outlines specific BMPs NCDOT must implement, a schedule for implementation, and annual reporting metrics.
NEW - TS4 (Transportation Separate Storm Sewer System) Mapping Program - the permit requires NCDOT to develop a
new program to map the components of its drainage system. The components include pipes, catch basins, open
channels, outfalls and flow direction. Mapping is required in the Phase I municipalities which include: Charlotte,
Winston-Salem, Greensboro, Durham, Raleigh, and Fayetteville/Cumberland Co area. Future permits may require
mapping in Phase II communities.
NEW - Spill Response Program - the permit requires NCDOT to develop and implement spill response procedures.
Although the Department has long had spill response procedures, they previously were not under the NPDES permit.
Coverage under the permit will necessitate more consolidated documentation and training. The spill response program
applies to non-roadway facilities. This would include office buildings, rest areas, maintenance yards, and the 4 industrial
facilities identified in the permit (Global TransPark, the rail maintenance facility in Raleigh, state owned asphalt plants,
and the Manns Harbor shipyard)
NEW - Fecal Coliform Reduction Program - the permit requires NCDOT to take specific actions at its non-road facilities
including connecting on-site wastewater systems to publicly owner treatment works where feasible, stormwater
pollution prevention training of wastewater facility operators, and maintaining pet waste stations.
NEW - Litter Management Program - the permit requires NCDOT to continue litter pickup activities, but requires new
actions such as quarterly litter inspections, identification of litter hotspots, and implementation of BMPs to prevent the
discharge of litter at hotspots.
NEW - TS4 Operation and Maintenance Program - the permit requires NCDOT to develop and implement a TS4 O&M
program designed to reduce the discharge of stormwater pollutants including particulates, sediment, litter, and debris.
The Department is required to identify high priority areas for implementation of BMPs to reduce pollutants. Improved
O&M documentation is required.
NEW - As-Built Policy - the permit requires the Department to develop a policy on preparing and storing as-built
drawings for stormwater control measures on TIP projects as well as retrofits.
TMDL Program - the permit provides greater flexibility for how NCDOT complies with TMDLs, but greatly expands the
number of TMDL waters NCDOT must respond to by now including TMDLs which do not name NCDOT as a significant
contributor of the pollutant of concern.
Annual Program Review - the permit continues to require NCDOT to annually evaluate and report on its NPDES
programs. But instead of a narrative format the annual report will be largely based on DEMLR approved performance
metrics.
Other Requirements - other requirements from the previous permit not mentioned above have been rolled over into
the renewed permit mostly unchanged.
Post-Construction Stormwater Program Updates
DEMLR approved a NCDOT proposed update to the PCSP on May 24, 2022.
NCDOT Policy/Procedural Changes:
• Revised roadway workflows to integrate with NCDOT’s Project Delivery Network (PDN) allowing for stormwater
treatment goals to be established earlier in the project development process.
• Updated text and figures to include procedures for the preparation of a preliminary stormwater management
plan (pSMP) to document the project’s stormwater treatment goals.
• Revised roadway workflows to require stormwater treatment goals to include implementation of stormwater
control measures to the MEP for certain watersheds. (Aquatic T&E species habitat, CA, HQW, ORW, SA, Tr,
UWL).
• Revised roadway workflows to include the use of the NC-SELDM Catalog for determining stormwater treatment
goals for all other waters.
• Included reference to the NCDOT BMP Decision Support Matrix as a tool to aid in the selection of appropriate
stormwater control measures.
• Revised guidance for non-roadway project in coastal counties distinguishing between receiving waters classified
as SA or non-SA
Where these documents can be found:
The new NPDES permit can be found here:
https://connect.ncdot.gov/resources/hydro/HSPPermits/2022_NPDES_Stormwater_Permit.pdf
or by Googling ‘ncdot npdes stormwater permit’
The updated PCSP can be found here:
https://connect.ncdot.gov/resources/hydro/HSPDocuments/2022_PCSP_Guidance_Final.pdf
or by Googling ‘ncdot pcsp’