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HomeMy WebLinkAboutNCS000545_Creedmoor Fall River Resolution_20220808 2018-R-20 MAYOR ROTIERTV.WHEELER CITY OF CREEDMOOR ' INTERIM P.O. Box 765 CI YMANAGER 111 MASONIC STREET KORENA L.WEICHEL CREEDMOOR,NC 27522 COMMISSIONERS ERNIEANDERSON W W W.CITYOFCREEDMOOR.ORG DEL MIMS (919)528-3332 NEENANOWELL HERMAN B.WILKERSON ARCHER WILKINS RESOLUTION 2018-R-20 Resolution Naming a Stormwater Administrator as Required Under the Falls New Development Stormwater Rule 15A NCAC 213 .0277 WHEREAS,the City of Creedmoor Board of Commissioners has adopted a local stormwater plan,approved by the North Carolina Department of Environment and Natural Resources Environmental Management Commission,that meets all statutory requirements of compliance with the Falls Reservoir Water Supply Nutrient Management Strategy: Stormwater Management for New Development(15A NCAC 2B .0277); and, WHEREAS,Under Article 19, Section 2, Subsection 19.14-1 of the Creedmoor Development Ordinance,the City Board of Commissioners shall designate a Stormwater Administrator to administer and enforce the provisions of said article; and, NOW THEREFORE, BE IT RESOLVED that on this 20th day of November,2018, the Board of Commissioners of the City of Creedmoor appoints Communitv Development Director Michael Franaos as Stormwater Administrator for the City of Creedmoor. Robert V. Wheeler, Mayor ATTEST: r ................ r KathTeen J. McCorkle, City Clerk ®��L. ' 1 •;c3� OFFICIAC i °a SFAS cl� o �r'en005 RE OvED tANU A �i ICi SHEVILLE. City of Creedmoor, North Carolina RECEIVED DEMLR-Stormwater Program Comprehensive Stormwater Management Plan Update In Support of the City's NPDES Phase II MS4 Permit No. NCS000545 40 Adopted April 511, 2022 RECEWE LAND QUALIFY SECTION ASHEVILLE i WHEREAS, the Board of Commissioners at the March 1, 2022 meeting moved to open a 35-day public comment period for the Stormwater Management Plan update, and set a public hearing on adoption of the Stormwater Management Plan for the April 5'h, 2022 Board of Commissioners meeting; and NOW THEREFORE BE IT RESOLVED by the City of Creedmoor Board of Commissioners that they do hereby: 1. Accepts the recommendation of the Planning Board for adoption of the Stormwater Management Plan 2. Adopt the Stormwater Management Plan update as presented. Adopted this the 51h day of April, 2022 , p Robert Wheeler, Mayor arbara Rouse, City Clerk ATTEST: ee6b�• ©� r�SEALAL RECEIVE® April 5th, 2022 " , Page 2 LAND UUTAU i r otLMON ASHEVILLE 6.2.3 Program Assessment...................................................................................21 Table 3 Best Management Practice for Public Involvement &Participation.............21 6.3 Illicit Discharge Detection&Elimination...........................................................23 6.3.1 IDDE Ordinance .........................................................................................24 6.3.2 Stormwater System Map.............................................................................24 6.3.3 Illicit Discharge Detection and Elimination Program...................................24 6.3.4 Employee Training......................................................................................26 6.3.5 Public Education and Outreach....................................................................26 6.3.6 Program Assessment...................................................................................26 Table 4 Best Management Practice for Illicit Discharge Detection& Elimination........ ..........................................................................................................26 &27 6.4 Construction Site Stormwater/Runoff Control....................................................29 6.5 Post Construction Stormwater Management-New Development and Redevelopment .........................................................................................................31 6.5.1 Post Construction Legal Authority..............................................................31 6.5.2 Stormwater Control Measures.....................................................................32 6.5.3 Stormwater Permit Plan Review..................................................................32 6.5.4 SCM Operation and Maintenance Program .................................................33 6.5.5 Program Assessment...................................................................................33 Table 5 Best Management Practice for Post Construction Stormwater Management .... ..........................................................................................................33 & 34 6.6 Pollution Prevention/Good Housekeeping for Municipal Operations..................36 6.6.1 Inventory of Municipal Facilities and Operations........................................36 6.6.2 Operations and Maintenance Program at Municipal Facilities .....................37 6.6.3 Street Sweeping Operations.........................................................................38 6.6.4 Municipal Owned Stormwater Control Measures and MS4 System.............38 6.6.5 Employee Staff Training.............................................................................39 6.6.6 Vehicle and Equipment Cleaning Operations ..............................................39 6.6.7 Program Assessment...................................................................................40 Table 6 Best Management Practice for Pollution Prevention/Good Housekeeping....... ..........................................................................................................40&41 RECEIVED [4] LAND QUALITY SECTION ASHEWLLE r 1 INTRODUCTION On February 1, 2018,the City of Creedmoor(City)received their second National Pollutant Discharge Elimination System(NPDES)permit (Permit No. NCS000545) from the State of North Carolina Department of Environmental Quality(NCDEQ), Division of Energy,Mineral, and Land Resources (DEMLR), authorizing them to discharge stormwater from the City's municipal separate storm sewer system(MS4) located within the City's corporate limits, to receiving waters of the State including Holman Creek, Beaverdam i Creek, Cedar Creek, Robertson Creek and Ledge Creek within the Neuse River Basin. These discharges must be in accordance with the discharge limitations, monitoring requirements, and other permit conditions including the development of this Stormwater Management Plan(SWMP). This permit and plan are effective until February 1, 2023. j I This SWMP is required by Part I,paragraphs A and G of the City's NPDES MS4 permit. A The objective of the SWMP is to establish how the permit requirements are implemented to achieve permit compliance. The SWMP plan details the program elements to be f implemented under the permit program and includes: the specific best management practices (BMPs) that are intended to fulfill the permit requirements; frequency of each f BMP; measurable program goals; implementation schedules; and responsible positions. v f The City's Department of Community Development is the primary agency responsible for f managing the City's NPDES MS4 permit, the MS4 system and the SWMP. Implementation of the requirements within the permit and SWMP activities are coordinated with the Department of Public Works and other applicable City departments as necessary. Funding for the BMPs specified in the SWMP is provided by local stormwater utility fees, I except where noted. The SWMP includes the following core NPDES MS4 permit programs: 1. Public Education and Outreach Program—This program provides the general public and businesses with information on general water quality, pollution prevention, and reporting problems, as well as specialized information on various activities that have the potential to [6] I i inspections and maintenance activities to ensure that treatment practices are properly operated and maintained. 6. Pollution Prevention/Good Housekeeping Program—This program focuses on ensuring that City facilities and field operations are managed in a way that minimizes stormwater pollutant discharges. Stormwater Pollution Prevention Plans and Spill Response Plans are maintained for applicable facilities that conduct activities with the potential for stormwater pollutant discharges. The City conducts inspections and training sessions at these facilities to ensure that requirements are being met. Good housekeeping measures such as street sweeping and off-site car washing have been implemented to reduce pollution. 2 BACKGROUND INFORMATION 2.1 Population Served The City serves a current population of approximately 4,800 people. This is the population based on information from the 2020 census. This data is located at htips://www2.census.goy/programs-surveys/decennial/2020/data/01-Redistricting_File-- PL 94-171/. Previous years of population data were found on the North Carolina Office of State Budget and Management website (https://files.nc.gov/ncosbnVdemop/muniestbymuni 2019.htm1). This population does not have seasonal variability. 2.2 Growth Rate The following table (Table 1)provides historic estimated population data for the City from the North Carolina Office of State Budget and Management website. According to this information, the population growth during the 9-year time period shown was 14%, or 1.5% per year(compounding). YEAR POPULATION 2020 4,866 2019 4,703 2010 4,124 Table 1. Population Data for the City of Creedmoor [8] associated outfalls. The system also has several privately-owned stormwater control measures (SCM) and one SCM owned and operated by the City, at the Creedmoor Community Center, built for the purposes of post-construction stormwater management, which were constructed to meet requirements of the NPDES permit and this SWMP. Upon completion of the map, this report will be updated to include a copy. ¢� ww1 Cr�NC OF 3 q A r . RV 1 4 Y Wooten Figure 2. MS4 Outfalls and Receiving Waters map for the City of Creedmoor 2.5 Land Use Composition Estimates Figure 2 is a zoning map of the City, which shows the various land uses within the City. The estimated size of these areas is provided in the further detail below. 1. Residential Land Use: 3.16 square miles 30.62% 2. Commercial Land Use: 0.68 square miles 6.59% 3. Industrial Land Use: 0.33 square miles 3.20% 4. Open Space: 6.15 square miles 59.59% [10] is to reduce concentrations of chlorophyll-a concentrations in the Lake. 3 RECEIVING STREAMS Stormwater from the City is discharged to following designated waters of the State (as shown on Figure 3): • Holman Creek • Beaverdam Creek • Cedar Creek • Robertson Creek • Ledge Creek • Whitaker Branch Rohortaon Creek t �� Holman Creek - t a Cedar Creek/ T pF. Beaverdam Creek �( Ledge Creek'j / - / Whitaker Branch N A 0 0375075 15 225 3 Miles Figure 4. City of Creedmoor Designated Waters of the State [12] 5.2 Responsible Party Contact Person Contact: Michael Frangos, AICP, CZO Title: Stormwater Administrator Street Address: III Masonic Street PO Box: PO Box 765 City: Creedmoor State: North Carolina Zip Code: 27522 Telephone: 919 764-1016 Fax Number: (919) 528-3052 E-mail Address: mfraneos@cityofcreedmoor.org 5.3 Signing Official Contact: Michael Frangos, AICP, CZO Title: Stormwater Administrator Street Address: I I I Masonic Street PO Box: PO Box 765 City: Creedmoor State: North Carolina Zip Code: 27522 Telephone: 919 764-1016 Fax Number: 919 528-3052 E-mail Address: mfrangos@cityofcreedmoor.ore 5.4 Duly Authorized Representative Under Article 19, Section 2, Subsection 19.14-1 of the Creedmoor Development Ordinance (Appendix A), the City Board of Commissioners shall designate a Stormwater Administrator. Michael Frangos, AICP, CZO, Community Development Director was duly appointed as the Stormwater Administrator for the City on November 2011, 2018, by the City Board of Commissioners. This plan will be updated upon any changes to this appointment. 6 STORMWATER MANAGEMENT PROGRAM 6.1 Public Education & Outreach on Storm Water Impacts Pursuant to Federal Regulations 40 CFR Section 122.34 (b)the City will implement a public education program to distribute educational materials to the community or conduct equivalent outreach activities about the impacts of storm water discharges on water bodies and the steps that the public can take to reduce pollutants in storm water runoff. [14] i I the City's NPDES permit, the stormwater hotline/belpline(as described in detail below) and links to public education materials (as described in detail below) and to additional information at the Clean Water Education Partnership (CWEP). 2. Public education materials. A wide variety of print media and promotional materials about water quality and pollution prevention will be maintained and provided to the public. This includes brochures and fact sheets. Print media and promotional I products will be distributed during public events,presentations, and/or through direct mail. 3. Public outreach events. The City's Community Development Office has previously presented a stormwater education booth at the annual Public Works Day event and City of Creedmoor Music Festival, distributed public education materials as described above, displayed a slide show regarding stormwater, and conducted demonstrations regarding impacts to stormwater from erosion. The City will continue to conduct public outreach events,these events may stay the same or change based upon the results of the annual program evaluation. 4. Mass media and social media. The City will continue to utilize several media sources to educate the public regarding stormwater. The City will maintain a contract with CWEP to produce and distribute an environmental education media campaign on local television stations. The City will publish one or more educational articles per year in the City's newsletter, Creedmoor Happenings. The City will post one or more articles per year on their Facebook page. 5. A stormwater hotline/helpline. The City will continue to i maintain a stormwater hotline/helpline and advertise it on the City's stormwater website. The City will also advertise the hotline/helpline on stormwater informational posters which will be displayed throughout the City. The City will maintain a [16] f� k v � � b :5 � � s •� Qj U N L 0l W � v C G � � �� m •g � v A a h � � � b v yy pC ❑ W y y 5 y z C byp •p _ T ° a° as 5 W o 0 o a o v ° CL oT c � -0 � 8a c � wog y � v ' dw d Ubo W S O T y ° A •p W O W A $ A A A A LL a a a a a a 7 a CL p � � EN M C N M tl N M C N M V+ N i-i C N In C ` NN.� Ud a.� Na•aO (`aJ3 WQ�•B V WPC.° �NJ 0 N C,4 0 (LJ NPR.° U w rJ' .r C Sj � C `J � C .�- � C 'J � C •� � C •y � C .� � O .,CCO A .,CCO _W W 7 O a � 9 O W b 00 yy ttl p U w o C -00 00 a5 C A0U :S A c{.� °y w o 8two N � a wOEoid m� v °3w E m o6 ow ctb cN .a- q . Wo vb ad •y v 9 � � ? w Wa 5 '3 ma � � N � w H .Ni N U v m o 5 .Y W � •� .5 A E � Department of Transportation's statewide cleanup. Local citizens are invited to participate in these events, which are advertised on the City website. b. Operation Medicine Drop. The City hosts a twice- annual collection of unused or expired prescription or over-the-counter medications to keep them out of landfills and from polluting local waterways. A Pharmaceutical drug disposal box is also located in City Hall for year round anonymous disposal of prescription medication. 2. An internet website. The City's will continue to maintain a "What You Can Do"page and link to a brochure educating citizens on what they can do to protect stormwater on their website. (httns•//www cityofcreedmoor orp-/departments-and- services/community-development/planning zoning/stormwater- proeram/what-yu-can-do) 3. Community Outreach. The City will continue to collaborate with the community during the development of City land conservation projects including conservation easements, greenway trails, other connections to open space in the City. These projects are supported by the Clean Water Management Trust Fund, the Triangle Land Conservancy, the North American Land Trust, and the Upper Neuse Clean Water Initiative. 4. A stormwater hotline/helpline. The City will continue to maintain a stormwater hotline/helpline which is advertised on the City's stormwater website. The City will also advertise the hotline/helpline on stormwater informational posters which will be displayed throughout the City. The City will maintain a tracker to track complaints and outcomes. Calls to any City office regarding stormwater will be routed to the Community Development office, and Community Development employees will provide stormwater education to citizens during the course of these calls. [20] E v wo ? E d o $ ,pp a alb y v m.y R LL g 'O .O N .5 a a E �' E � o � w �a m v a w m y v h to v W .a � ,o .9j .9W>4 v � C y v °' �3 � v •g o ° •5 •y a E fV L U O � .� µ U a u WL GG � W a a A m E o o o m E o •� a pa � y '� w � � �.E A .5 •05 .5 � t0 � � tiq� •°' m 5 a3 U N 10 .� •o m o o,'� W � .E w v a 6 � N ptb 0 a O 3 c RECEIVED 08 m p g e 5 LAND QUALITY SECTION g ASHEVILLE H oo w � a � p 14)flows from riparian habitats and wetlands, 15)de-chlorinated swimming pool discharges, and 16)street wash water 17)Exceptions include: discharges or flows from fire-fighting activities (excluded from the effective prohibition against non-storm water and will only be addressed where they are identified as significant sources ofpollutants to waters ofthe United States). The following sub-sections explain: • The BMPs intended to meet program requirements; • Integral components of the IDDE program; • Education strategy; and • Program Assessment. 6.3.1 IDDE Ordinance The City adopted its Watershed Protection Ordinance (Article 19) on June 18, 2012 and subsequently amended the Ordinance on November 20, 2018 per Ord. 2018-0- 09, ZTA-2018-05. Section 6 of this ordinance specifically addresses Illicit Discharges. This ordinance is enforced as part of the NPDES MS4 permit and SWMP. Detailed administration, remediation and enforcement procedures are maintained for the ordinance. 6.3.2 Stormwater System Map The City has contracted with The Wooten Company to produce a map of the City's MS4 stormwater system. The City will maintain and update the inventory of its MS4 system using Geographic Information Systems (GIS) which includes data for major outfalls and sub-basins. New stonnwater infrastructure will be entered into the GIS inventory for new development projects. Inventory data will be stored and maintained digitally. Hard copy maps showing major outfalls and receiving streams can be produced as needed. This report will be updated with a copy of the map once it has been completed RECEIVED 6.3.3 Illicit Discharge Detection and Elimination Program The City will continue to implement their IDDE program in the followingMUALI T Y SECTION [24] ASHEVILLE i i 6.3.4 Employee Training Training about illicit discharges will continue to be provided to a variety of City employees, including Public Works and Stormwater Administration staff, and typically includes: •How to recognize common illicit discharges; • Their impact on surface water quality; •Why protecting surface water is important for the community; •Pollution prevention practices; •How to report illicit discharges;and i •How these reports are investigated and enforced. The City will continue to update information on employee training including names of courses, dates, and certifications. 6.3.5 Public Education and Outreach The City will continue to maintain a public education and outreach program to inform businesses and the general public about illicit discharges and improper waste disposal and how they impact the environment. This education and outreach { program includes instructions regarding the proper method for reporting illicit discharges on the City's website. Public education and outreach items for the IDDE { Program are included as a component of the Public Education and Outreach Program described in Section 6.1 above. 6.3.6 Program Assessment The overall success of the IDDE Program is evaluated through the successful implementation of the components of the program and reported with each NPDES I MS4 annual report. Additional information regarding program assessment can be found in Table 4 below. [26] N o C 0 0 P O G A o C ti 0 0 W O W d O y 0 O p b � g •5g w da c v � '� �i .5c Ca •5 .5 � W a Q a N �+ q G G 41 ar FE °'•� s o ., m o 591. ao � d bo 5 u 5 0 g E - $ 00 � o ob � g � gg gR '� pb N o v00 goAa '� gr d on ❑ �, .A .o AFp � as= ,� pn� �i 5 ,,, �' w'`-. .0 tj y El aR_ N W N ."J' V d qAG p E u C ti O L m C la m N ..N. .b •U U A 0 ,0 A p i0 A A o p y •o A N s7A o v .L g = � � •U � .� u g N � r+ .r N N Asa .5 G .� � a � •$ � wv E y y .r 5 v zoo pw Ow o A Et� ^ 'E � w .9 A w 'o E N a E p U U pp W m > a �' F `" S •o o •5 a o tii � i c) The other entity agrees to implement the control measure on behalf of the MS4. Pursuant to State Requirements in Session Law 2006-246 Section 7 "to obtain a Phase II National Pollutant Discharge Elimination System (NPDES)permit for storm- water management,[the city] shall,to the extent authorized by law, develop, implement, and enforce a stormwater management plan approved by the Commission that satisfies the six minimum control measures required by Code 40 of Federal Regulations §122.34(b)(1 July 2003 Edition)." Regulated entities may propose using any existing State or local program that relates to the minimum measures to meet, either in whole or in part, the requirements ofthe minimum measures. i The NCDEQ Division of Land Resources Erosion and Sediment Control Program effectively meets the requirements of the Construction Site Runoff Controls in the City of Creedmoor by permitting and controlling development activities disturbing one or more acres of land surface and those activities less than one acre that are part of a larger common plan of development. This program is authorized under the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code. This program includes procedures for public input, sanctions to ensure compliance, requirements for construction site operators to implement appropriate erosion and sediment control practices, review of site plans I which incorporates consideration of potential water quality impacts, and procedures for site inspection and enforcement of control measures.The NCGO 10000 permit establishes requirements for construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals,litter, and sanitary waste at the construction site that may cause adverse impacts to water quality. j I i [30] i f i I 6.5.2 Stormwater Control Measures BMP strategies for the City's Post-Construction Stormwater Management program will consist mainly of structural stormwater control measures(SCMs) such as sand filters, wet ponds, wetlands, and bioretention areas. SCMs should be designed in accordance with the NC Department of Environmental Quality Stormwater Design Manual(NCDEQ BMP Manual). SCMs will be required on projects that have high density development and disturb more than one-half acre of land for residential or recreational development that is not part of a larger common plan of developer or sale or disturb more than 12,000 square feet of land for non- residential/recreational developments that are not part of a larger common plan of development or sale. In addition, SCMs must be designed to: c • Reduce Nitrogen and Phosphorus loads to not exceed 2.2 and 0.33 pounds per acre per year, respectively; i Control and treat the runoff generated from all surfaces by one inch of rainfall; • Control the peak flow from the 1-year—24-hour storm event; and • Convey the runoff from the 10-year storm event without surcharging the drainage system. The program will also require proper operation, maintenance, and inspection of I SCMs as discussed in Section 6.5.4 below. 6.5.3 Stormwater Permit Plan Review For a stormwater permit to be reviewed and issued by the City of Creedmoor, several documents must be submitted. The documentation required to apply for a stormwater permit consists of • City Stormwater Permit Application; • SNAP Tool(an interactive Excel spreadsheet that calculates nutrient reduction); •Three (3) sets of plans; •A copy of the operations and maintenance manual for the engineered SCM's proposed; •Application fee(as listed in the City's Fee and Rate Schedule) [32] a 'ti � -a' tm o o ° •� l U 'd um N tMl t' d ,7 N CUC C V C y 7 Ap � N ''J « zip ❑ z U ° c U U b Uw � Ey ° �a o Y m C > j 00'�' C N a m 5 0.E Riw 5 y C ^ a � 9 .5 „ eon ° �J m yIL Qwa° afimOvv 5a v � as � _ fi a 0 � 3 w " � eE ,n° EA t m $ a h aoQo �V 5 azy O N C C � 2a > � � w 0 � o " �' « ° E W d d V E r W U d V+ A W ,ti ° ° d C ° 0.Ni .'d v w y qm C .-. ... �+ 'ggam lUd 'J O .�, m b C 3 A 8 Coj m � � ° � y 'Sv .9Am ° . � � w yco :o � g, N gg 41 �. Oz � o Q A b •bE � 95 d9 �wAp 0 t = 0a� � A $ Kw �3A awPa � o � � 5d � E5a � v ca •o oo o .E ^ o A ❑ e fi � v � v v v � A 'tpU C o v u E A A E 9 .� .5 0. ZA � FyN E °o � ° dE �N bo � °rn? E ° vmm y A � y O O o y $ U o a y N � gWs yw � •oQ � w my ° o O•C y �Ci A C. � A U h G � p U 6.6 Pollution Prevention/Good Housekeeping for Municipal Operations Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the city will develop and implement an operation and maintenance program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from municipal operations.Using training materials that are available from EPA, the State of North Carolina,or other organizations, our program will include employee training to prevent and reduce stormwater pollution from activities such as park and open space maintenance,fleet and building maintenance,new construction and land disturbances, and storm water system maintenance. The following sub-sections explain: • The BMPs intended to meet program requirements; • Integral components of the program; • Employee education and training; and • Program assessment. 6.6.1 Inventory of Municipal Facilities and Operations The City provides an extensive network of municipal operations designed to serve its citizens and keep vital infrastructure functioning properly. All parcels of land owned or operated by the City are examined to determine whether they are included in the Municipal Facilities Inventory within the Pollution Prevention/Good Housekeeping Program. A Standard Administrative Procedure is followed when evaluating parcels for this inventory. Once included in the inventory, facilities will receive: • Preparation and implementation of a Stormwater Pollution Prevention Plans (S WPPP); • Regular inspections; and [36] i i i personnel, typically a supervisor and/or management personnel, will participate in inspections and will be responsible for implementation of SWPPPs and best management practices. 6.6.3 Street Sweeping Operations Streets can be a significant source of stormwater pollution, particularly leaves, which can contribute nitrogen and phosphorus (the City's target pollutants)to local i waterways. In order to address this source,the City will continue to conduct street sweeping operations. The City will continue to contract with American Road Conservation to provide quarterly vacuum truck sweeping for all residential areas where curb and gutter are present. The City will continue to maintain documentation regarding each sweeping event including miles swept and pounds of debris collected. The City is in the process of developing an evaluation program for its street sweeping operation, with the goal of determining the amount of nitrogen i and phosphorus removed from their roadways on an annual basis. This information i will be utilized to determine if street sweeping operations should be adjusted for future permit years. f I 6.6.4 Municipal Owned Stormwater Control Measures and MS4 System j The City currently has one municipally owned SCM, located at the Creedmoor Community Center. This SCM is inspected several times per year. Maintenance is conducted as needed based on inspection results. Standard inspection forms are ! used to conduct and document inspections with this information maintained in a database. The City's Public Works staff will continue to conduct cleaning and maintenance of the MS4 system. Services will include,but will not limited to: • Catch basin cleaning(manually and with jet trucks); [38] i and most larger pieces of vehicle equipment. AutoBrite car washes are self-service j car washes with a discharge capture system i 6.6.7 Program Assessment The overall success of the Pollution Prevention and Good Housekeeping Program is evaluated through the successful implementation of the components of the program j i and reported with each NPDES MS4 annual report. Additional information i regarding program assessment can be found in Table 6 below. I i I I [40] c C A ° 9 0 Av x > a N xx � W o � 9] .9 = b S « « m °. a S W (n N L m 'b Tw v ° w o Oro10, N W G d u to dv 5 E! R .g ° GSpa � > > �C � oN 'a �p 0 .2 m S'. a _� ' 9 C a v E m 9 A •9 c m � C O ��Ci •5 U •� m p C on E N