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HomeMy WebLinkAboutNCS000495_Holly Springs 2004 Permit Application_20040506Town of Holly Springs, North Carolina NPDES Phase II Stormwater Application May 6, 2004 NORTH CAROLINA Developed By: The Town of Holly Springs, Department of Engineering Stephanie L. Sudano, P.E., Director of Engineering Heather V. Keefer, CFM, Environmental Specialist 128 S. Main Street P.O. Box 8 Holly Springs, NC 27540 919.557.3938 - fax 919.552.9881 www.townofhollyspringsnc.net Copy ' of (^1 LI TABLE OF CONTENTS Application STORM SEWER SYSTEM INFORMATION 1.1. Population Served 1.2. Growth Rate 1.3. Jurisdictional and MS4 Service Areas 1.4. MS4 Conveyance System 1.5. Land Use Composition Estimates 1.6. Estimate Methodology 1.7. TMDL Identification 2. RECEIVING STREAMS 3. EXISTING WATER QUALITY PROGRAMS 3.1. Local Programs 3.2. State programs 4. PERMITTING INFORMATION 4.1. Responsible Party Contact List 4.2. Organizational Chart 4.3. Signing Official 4.4. Duly Authorized Representative Co -Permitting Information (if applicable) 5.1. Co-Permittees 5.2. Legal Agreements 5.3. Responsible Parties 6. Reliance on Other Government Entity 6.1. Name of Entity 6.2. Measure Implemented 6.3. Contact Information 6.4. Legal Agreements STORMWATER MANAGEMENT PROGRAM 7.1. Public Education and Outreach on Storm Water Impacts 7.2. Public Involvement and Participation 7.3. Illicit Discharge Detection and Elimination 7.4. Construction Site Stormwater Runoff Control 7.5. Post -Construction Storm Water Management in New Development and Redevelopment 7.6. Pollution Prevention/Good Housekeeping for Municipal Operations Page 1 Town of Holly Springs, NPDES Phase II Application May 6, 2004 Appendix A BMPs and Measurable Goals Table Attachments 1. Responsible Party Contact List 2. Organizational Chart 3. Sediment and Erosion Control Ordinance 4. Flood Damage Prevention Ordinance 5. Town of Holly Springs Riparian Buffer Regulations & Stream Protection Plan 6. Unified Development Ordinance/ Development Procedures Manual - on CD 7. 1998 10-year Comprehensive Growth Plan - on CD 8. Hydrologic Basin Models Policy Statement P-18 and basin model pictures 9. Water Shortage & Conservation Ordinance 10. Open Space Master Plan 11. Town of Holly Springs Engineering Design Standards and Specifications: Section 4 - Sedimentation and Erosion Control, Section 10 - Environmental Page 2 SWU-264-103102 State of North Carolina Department of Environment & Natural Resources Division of Water Quality OFFIC USE ONLY Date Reed ��p Fee Paid Permit Number pp ' NPDES STORMWATER PERMIT APPLICATION FORM This application form is for use by public bodies seeking NPDES stormwater permit coverage for Regulated Public Entities (RPE) pursuant to Title 15A North Carolina Administrative Code 2H .0126. A complete application package includes this form and three copies of the narrative documentation required in Section X of this form. This application form, completed in accordance with Instructions for completing NPDESSmall M54 Stormwater PermitAppiicabon (SWU-270) and the accompanying narrative documentation, completed in accordance with Instructions for Preparing the Comprehensive Stormwater Management Program Report (SWU-268) are both required for the application package to be considered a complete application submittal. Incomplete application submittals may be returned to the applicant. I. APPLICANT STATUS INFORMATION a. Name of Public Entity Town of Holly Springs Seeking Permit Coverage b. Ownership Status (federal, local state or local c. Type of Public Entity (city, Town town, county, prison, school, etc. d. Federal Standard Industrial SIC 91 - 97 Classification Code e. County(s) Wake f. Jurisdictional Area (square miles Approximately 14.5 PP Y square miles g. Population Permanent 13,500 Seasonal (if available) N/A h. Ten-year Growth Rate 79.77% (Annual growth rate for the period 1990 - 2000) i. Located on Indian Lands? ❑ Yes ® No II. RPE / MS4 SYSTEM INFORMATION a. Storm Sewer Service Area (square miles 8,3 square miles b. River Basin(s) Neuse River Basin (25%) & Cape Fear River Basin (75%) c. Number of Primary Receiving Streams Neuse (3), Cape Fear (7) d. Estimated percentacie of iurisdictional area containing the following four land use activities: • Residential 33% • Commercial 6.1% • Industrial 11.7% • Open Space 50.8% Total e. Are there significant water quality issues listed in the attached application report? ® Yes ❑ No SWU-264-103102 Page 2 NPDES RPE Stormwater Permit Application III. EXISTING LOCAL WATER QUALITY PROGRAMS a. Local Nutrient Sensitive Waters Strategy ❑ Yes ® No b. Local Water Supply Watershed Program ❑ Yes ® No c. Delegated Erosion and Sediment Control Program ® Yes ❑ No d. CAMA Land Use Plan ❑ Yes ® No ** Revised land use percentages will be available at the 4/20/04 town board meeting TV. CO -PERMIT APPLICATION STATUS INFORMATION (Complete this section only if co -permitting) a. Do you intend to co -permit with ❑ Yes ® No a permitted Phase I entity? b. If so, provide the name and permit number of that entity: • Name of Phase I MS4 N/A • NPDES Permit Number N/A c. Do you intend to co permit Yes ®No with another Phase II enti ? d. If so, provide the name(s) of N/A the entity: e. Have legal agreements been finalized between the co- ❑ Yes ® No ermittees? V. RELIANCE ON ANOTHER ENTITY TO SATISFY ONE OR MORE OF YOUR PERMIT OBLIGATIONS (If more than one, attach additional sheets) a. Do you intend that another entity perform one or more of our permit obligations? ❑ Yes ® No b. If yes, identify each entity and the element they will be implementing • Name of Entity N/A • Element they will implement N/A • Contact Person N/A • Contact Address N/A • Contact Telephone Number N/A c. Are legal agreements in place to establish responsibilities? El Yes ®No VI. DELEGATION OF AUTHORITY (OPTIONAL) The signing official may delegate permit implementation authority to an appropriate staff member. This delegation must name a specific person and position and include documentation of the delegation action through board action. a. Name of person to which permit authority has been delegated b. Title/position of person above c. Documentation of board action delegating permit authority to this person/position must be provided in the attached application report. Page 2 SWU-264-103102 NPDES RPE Stormwater Permit Application VII. SIGNING OFFICIAL'S STATEMENT O� , Please see the application instructions to determine who has signatory authority for this permit application. If authority for the NPDES stormwater permit has been appropriately delegated through board action and documented in this permit application, the person/position listed in Section VI above may sign the official statement below. I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properlygather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible forgathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. lam aware that there are significant penalties forsubmitting false information, including the possibility fines and imprisonment for knowing violations. Signature _ /J p / Name Carl Dean Title Town Manager Street Address 128 S. Main St. PO Box P.O. Box 8 City Holly Springs State NC Zip 27540 Telephone (919) 557-3903 Fax (919) 567-1472 E-Mail Carl. DeanCalncmail.net VIII. MS4 CONTACT INFORMATION Provide the following information for the person/position that will be responsible for day to day implementation and oversight of the stormwater program. a. Name of Contact Person Stephanie L. Sudano, P.E. b. Title Director of Engineering c. Street Address 128 S. Main St. d. PO Box P.O. Box 8 e. City Holly Springs f. State NC g. Zip 27540 h. Telephone Number (919) 557-3938 L Fax Number (919) 552-9881 j. E-Mail Address Stenhanie.SudanoCalncmail.ri Page 3 SWU-264-103102 NPDES RPE Stormwater Permit Application IX. PERMITS AND CONSTRUCTION APPROVALS List permits or construction approvals received or applied for under the following programs. Include contact name if different than the person listed in Item VIII. If further space needed, attach additional sheets. a. RCRA Hazardous Waste N/A Management Program N/A b. UIC program under SDWA c. NPDES Wastewater Discharge NPDES Permit NCO063096 Permit Number d. Prevention of Significant N/A Deterioration (PSD) Program N/A e. Non Attainment Program f. National Emission Standards for N/A Hazardous Pollutants (NESHAPS) reconstruction approval g. Ocean dumping permits under the N/A Marine Protection Research and Sanctuaries Act h. Dredge or fill permits under Individual permits are applied for as needed for Town section 404 of CWA construction projects including road projects X. NARRATIVE APPLICATION SUPPLEMENT. STORMWATER MANAGEMENT PROGRAM REPORT Attach three copies of a comprehensive report detailing the proposed stormwater management program for the five-year permit term. The report shall be formatted in accordance with the Table of Contents shown below. The required narrative information for each section is provided in the Instructions for Preparing the Comprehensive Stormwater Management Program Report (SWU-266). The report must be assembled in the following order, bound with tabs identifying each section by name, and include a Table of Contents with page numbers for each entry. TABLE OF CONTENTS 1. STORM SEWER SYSTEM INFORMATION 1.1. Population Served 1.2. Growth Rate 1.3. Jurisdictional and MS4 Service Areas 1.4. MS4 Conveyance System 1.5. Land Use Composition Estimates 1.6. Estimate Methodology 1.7. TMDL Identification 2. RECEIVING STREAMS 3. EXISTING WATER QUALITY PROGRAMS 3.1. Local Programs 3.2. State programs Page 4 SWU-264-103102 NPDES RPE Stormwater Permit Application 4. PERMITTING INFORMATION 4.1. Responsible Party Contact List 4.2. Organizational Chart 4.3. Signing Official 4.4. Duly Authorized Representative 5. Co -Permitting Information (if applicable) 5.1. Co-Permittees 5.2. Legal Agreements 5.3. Responsible Parties 6. Reliance on Other Government Entity 6.1. Name of Entity 6.2. Measure Implemented 6.3. Contact Information 6.4. Legal Agreements 7. STORMWATER MANAGEMENT PROGRAM 7.1. Public Education and Outreach on Storm Water Impacts 7.2. Public Involvement and Participation 7.3. Illicit Discharge Detection and Elimination 7.4. Construction Site Stormwater Runoff Control 7.5. Post -Construction Storm Water Management in New Development and Redevelopment 7.6. Pollution Prevention/Good Housekeeping for Municipal Operations Page 5 SWU-264-103102 THE TOWN OF HOLLY SPRINGS CARL DEAN, TOWN MANAGER P.O. BOX 8 HOLLY SPRINGS, NC 27540-0008 Carl Dean: Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality 11/6/2002 FRIEE3VD NOV 1 2 7002 ENGINEERING Subject NPDES Phase II Stormwater Program 2000 U.S. Census - Notification of Coverage In 1990 the U.S. Environmental Protection Agency's (EPA) Phase I stormwater program was promulgated under the Clean Water Act. Phase I relies on National Pollutant discharge Elimination System (NPDES) permit coverage to address stormwater runoff from: (1) "medium" and "large" municipal separate storm sewer aystems (MS4s) generally serving populations of 100,000 or greater, (2) construction activity disturbing 5 acres of land or greater, and (3) ten categories of industrial activity. The NPDES Stormwater Phase II Final Rule was promulgated in December 1999 and is the next step in EPA's effort to preserve, protect, and improve the Nation's water resources from polluted stormwater runoff. The Phase II program expands the Phase I programby requiring additional operators of MS4s in urbanized areas and operators of small construction sites, through the use of NPDES permits, to implement programs and practices to control stormwater runoff. Phase II is intended to further reduce adverse impacts to water quality and aquatic habitat by instituting the use of controls on the unregulated sources of storm water discharges that have the greatest likelihood of causing continued environmental degradation. The NPDES Stormwater Phase ll Final Rule requires nationwide coverage of all operators of small MS4s that are located within the boundaries of a Bureau of the Census defined "urbanized area" based on the latest decennial Census. The Bureau of Census has recently released data detailing the 2000 Census urbanized areas and using GIS data files produced by the Bureau of Census, North Carolina Department of Environment.and Natural Resources staff has compiled a list of municipalities and counties that we believe fall in whole or in part within one or more of the seventeen census -designated urbanized areas in North Carolina. We are writing to you to notify you that the Town of Holly Springs has been identified as being located within a census designated urbanized area. As a regulated community, you are required to develop a stormwater management program and apply for stormwater permit coverage, if you own and operate a small MS4 or file a certification that the Town of Holly Springs does not own or operate a small MS4. The deadline for submitting your application package or non -ownership certification is 18 months from the date of this letter. Application and certification documents, as well as additional information on the NPDES stormwater program, are available for download at our web site. Our web address is http://h2o.enr.state.nc.us/gulstormwawr.htrnl. If you have any questions about this letter, please feel free to contact me (919-733-5083, ext.525) or Darren England (919-733-5083, ext. 545) Sincerely, Bradley Bennett, Supervisor NOV 12 2002 Stormwater and General Permits Unit cc: Central Files TOWN MANAGER Stormwater and General Permits Unit Files A Raleigh Regional Office+'Fii,,, ICC WRI N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service 1-800-623-7748 C �,� NARRATIVE APPLICATION SUPPLEMENT: STORMWATER MANAGEMENT PROGRAM REPORT 1. STORM SEWER SYSTEM INFORMATION 1.1. Population Served: The permanent population for the Town of Holly Springs in 2004 is estimated to be approximately 13,500 per the Town of Holly Springs population projections. Population projections have been based on the average number of building permits issued over the past three (3) Fiscal Years added to 2000 Census data. Population projections are based on Building Permits multiplied by 2.77 persons per household. (2000 Census Data indicated an average of 2.77 persons per household) 1.2. Growth Rate: The growth rate for the service area is calculated based on the simple analysis of the relative change between the US Census population in 1990 and 2000 stated as a percent change, annualized by dividing the percent change by 10 yields a growth rate of 79.77%. 1990 census population was 1,024; 2000 census population was 9,192. Total change for the 10 year period was 797.7%. 1.3.Jurisdictional and MS4 Service Areas: The jurisdictional area is approximately 14.5 square miles this area includes city limits and the Town's ET]. The. MS4 service area is approximately 8.3 square miles. 1.4. MS4 Conveyance System: Downtown Holly Springs lies on the watershed divide between two major river basins: Middle Creek and its tributaries (Basal Creek, and Rocky Branch,) in the Neuse River basin, drain the eastern one-fourth of the Holly Springs planning area. Buckhorn Creek and its tributaries (White Oak Creek, Big Branch, Little Branch, Utley Creek, and Cary Branch,) in the Cape Fear River basin, drain the western three -fourths of the planning area. NC-55 north of Holly Springs and SR 1115 and SR 1101 south of Town lie along the watershed divide between these two river basins. Rainfall to the east of this divide flows to the Neuse River, and rainfall to the west of the divide flows to Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 1 of 27 the Cape Fear River. Stormwater is collected via open swales and ditches, curb and gutter, or yard inlets to a closed system of pipes with flared end sections. Some flared end sections outlet into stormwater (Best Management Practices) BMPs, such as level spreaders or riparian buffers. A predominant amount of the streams in the Neuse River Basin flow through Bass Lake and/or Sunset Lake, prior to leaving the Town's service area. Most streams in the Cape Fear River Basin drain into Harris Lake prior to reaching the Cape Fear River. The Town regulates all stormwater collection system design and construction. The Town maintains all storm water systems on Town property and within its street rights -of -ways. The Public Works Department maintains these areas as needed to keep inlets clear of debris. Stormwater systems within the State's right-of-way is maintained by the North Carolina Department of Transportation. Systems on private property or private drainage easements are solely the landowner's responsibility. The Town may take corrective action on these systems when improper maintenance is causing emergency situations. The property owner may then be subsequently billed for these activities. Proper maintenance includes insuring that outfalls are free from obstructions, and securely in accordance with local, state, and federal regulations. 1.5. Land Use Composition Estimates: LAND USE ACRES PERCENT Residential 2095.6 31.3% Commercial 569.6 6.1% Industrial 1088 11.7% Open Space 4716.8 50.8% 1.6. Estimate Methodology: For this project, the existing land use inventory was determined using GIS data based upon parcel information provided by Wake County to determine the estimated land use for parcels within the Towns corporate limits and ETI The GIS information used to determine the land use was a combination of current zoning district data as well as subdivision and site plans data. Residential classification is based upon the existing subdivision and those subdivisions that are currently under construction. The commercial area is based upon existing commercial property as well as approved site plans. The industrial classification includes existing includes existing industrial properties, land fills and quarries. The open space includes .83 square miles 5.7% of Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 2 of 27 developed open space such as school, parks and cemeteries. The remainder of the open space classification are undeveloped and under developed properties. Currently the Town's Land Use Plan is being revised. With the use of new tools such as the Town's GPS/GIS utility mapping program and the development tracking software we anticipate obtaining more current land use data in the future. 1.7.TMDL Identification: The Town of Holly Springs discharges into Middle Creek which has its confluence with Swift Creek East of NC 210 in Johnston County. It is our understanding that a Swift Creek Watershed assessment is underway by NC DENR to determine sources of impairment and potentially develop TMDL. Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 3 of 27 m 2. RECEIVING STREAMS Table 1. Neuse River Basin Receiving Stream Stream Water Quality se Support Water Quality Name Segment Classification Issues Ratin Middle Creek 27-43-15-(1) C; NSW From source to backwaters of Sunset Lake Middle Creek 27-43-15-(1) B; NSW Sunset Lake Middle Creek 27-43-15-(4) C; NSW From dam at Sunset Lake to Swift Creek Aquatic Life/ Middle Creek z002 - 1�4 Impair Subbasin 03-04-03 Secondary Miles Recreation Basil Creek 27-43-15-3 B• NSW Not rated Rocky Branch 27-43-15-4.5 C• NSW Not rated • information for this table has been obtained from the NC DENR 2001 Neuse River BasinWde Water Quality Plan Table 2. Cape Fear River Basin Receiving Stream Stream Water Quality Water Quality Name Segment Tiication Support Issues ,,C Ratin Buckhorn Creek 18-7- 3 WS-V Not rated White Oak Creek 18=7-6 C Not rated Big Branch 18-7-6-1 C Not rated Little Branch 18-7-6-1 C Not rated Utley Creek 18-7-5.5 C Not rated The "Cape Fear River Basinwide Water Quality Plan"- July, 2000 addresses water quality impacts (DO, TP, TN) from 1994- 1997 in Utley Creek below Holly Springs' WWTP. Nutrient limits have been assigned to that facility for subsequent upgrade(s). No recent WQ issues reported. Cary Branch 18-7-5 C Not rated Norris Branch 18-7-5-1 C Not rated • information for this table has been obtained from the NC DENR 1999 & 2000 Cape Fear River Basinwide Water Quality Plan Town of Holly Springs, North Carolina May 6, 2004 NPDES Stonnwater Permit Application 4 of 27 C = Secondary Recreation B = Primary Recreation NSW = Nutrient Sensitive Waters Information Sources: Stream Index Numbers: htto://h2o.enr.state.nc.us/bims/Reports/reportsWB.html Water Quality Classifications httii://h2o.enr.state.nc.us/bims/Reports/reportsWB.htmi Basinwide Water Quality Plans: http://h2o.enr.state.nc.us/basinwide/index.htmi 303(d) List: htto://h2o.enr.state.nc.us/mtu/download.html Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 5 of 27 3. EXISTING WATER QUALITY PROGRAMS 3.1. Local Programs: ■ Local Sedimentation and Erosion Control Program: Delegated by the Sediment Control Commission - attachment #3 - • Flood Damage Prevention Ordinance - attachment #4 ■ Town -mandated riparian buffer regulations: Section 7.06 of the Town of Holly Springs Unified Development Ordinance - attachment #5 ■ Unified Development Ordinance - attachment #6 ■ 1998 Ten-year comprehensive growth plan - attachment #7 ■ Drainage Policies: Including the use of three drainage basin HEC-HMS models to identify changes in surface water elevation and provide information to ensure that new development will not negatively affect adjacent properties - attachment #8 ■ Water Conservation Ordinance - attachment #9 • Town of Holly Springs Master Open Space Plan - attachment #10 • Engineering Standards and Specifications - Section 4 - Sedimentation and Erosion Control, Section 10 - Environmental Copies of ordinances and policies for the existing water quality programs are available in the attachment section of the application. 3.2.State programs: ■ Neuse Riparian Buffer Rules ■ Erosion and Sedimentation Control (for all construction projects one acre of disturbed area or greater that are not permitted through the Town of Holly Springs) Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 6 of 27 4. PERMITTING INFORMATION 4.1. RESPONSIBLE PARTY CONTACT LIST Please refer to Attachment 1 4.2.Organizational Chart Please refer to Attachment 2 4.3.Signing Official: Carl Dean, Town Manager The Town Manager is the appropriate person to sign the application as this position has direct supervision and management control over those departments that have roles and responsibilities in the administration of this program. Please refer to Attachment 3: Resolution of the Holly Springs Town Board of Commissioners authorization to Submit National Pollutant Discharge Elimination System Phase II Permit Application and Stormwater Management Plan 4.4. Duly Authorized Representative- N/A Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 7 of 27 L.} THE TOWN OF Holly Springs APR 2 6 2004 ENGINEERING P.O. Box 8 128 S. Main Street Holly Springs, N.C. 27540 (919)552-6221 Fax: (919)552-5569 Mayor's Office Fax: (919)552-0654 I certify this to be a true copy of the original. Resolution No.: 04-18 Date Submitted: April 20, 2004 I, Al ?,, ./„Town Clerk Holl Springs, NCDate Adopted: A RESOLUTION OF THE HOLLY SPRINGS TOWN BOARD OF COMMISSIONERS AUTHORIZING SUBMISSION OF NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PHASE H PERMIT APPLICATION AND STORMWATER MANAGEMENT PLAN WHEREAS, the United States Congresi passed the Clean Water Act in 1972 and amended said Act in 1987 to address controls for pollution carried by stornawater; and, WHEREAS, the Environmental Protection Agency (EPA) was authorized to define and prescribe a program of measures to improve the quality of water in our national and state streams, rivers and water bodies under the National Pollutant Discharge Elimination System (NPDES) and promulgated Phase II rules on December 9, 1999 affecting communities and institutions under 100,000 population; and, WHEREAS, the State of North Carolina is delegated by EPA to establish a regulatory program for NPDES Phase H and has established rules and regulations as required; and, WHEREAS, the Town of Holly Springs has been notified of and is legally designated to comply with the NPDES Phase H regulations as established by EPA and the State, requiring the submittal of a permit application and stormwater management plan; and WHEREAS, the regulations require designation of the legally responsible party and authorization for submittal of the application and stormwater management plan; and WHEREAS, the Holly Springs Town Board of Commissioners supports the goals and objectives of the regulatory program to provide a safe and healthy environment for all its citizens; NOW, THEREFORE, BE IT RESOLVED by the Holly Springs Town Board of Commissioners the following: 1) That Holly Springs Town Manager Carl Dean, or his designee, shall sign and submit on behalf of the Town of Holly Springs, North Carolina, no later than May 6, 2004, the necessary documentation for compliance with the NPDES Phase II program requirements as established by the State; and 2) That Holly Springs Town Manager Carl Dean, or his designee, shall carry out all necessary strategie &enlss set forth in the stormwater manage submitted as required by the �a, to ensure compliance on North Carolina. Adopted this, the 20th day of Powell, CMC, Town Clerk S. Co -Permitting Information (if applicable) 5.1.Co-Permittees - N/A 5.2. Legal Agreements - N/A 5.3. Responsible Parties - N/A Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 8 of 27 r-' 6. Reliance on Other Government Entity 6.1. Name of Entity - N/A 6.2. Measure Implemented - N/A 6.3.Contact Information - N/A 6.4. Legal Agreements - N/A Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 9 of 27 ("I 7. STORMWATER MANAGEMENT PROGRAM To protect water quality the Town of Holly Springs will develop, implement, and enforce a stormwater management program (SWMP) designed to reduce the discharge of pollutants from Holly Springs to the maximum extent practicable (MEP) and to satisfy the appropriate water quality requirements of the Clean Water Act. The stormwater management program will be developed and fully implemented within five years from the effective date of the issued NPDES stormwater permit. 7.1. Public Education and Outreach on Storm Water Impacts 7.1.1. BMP Summary Table: Appendix A 7.1.2. Target Audience: The target audiences for our education program will be those likely to have significant storm water impacts. These include: commercial, industrial, residential development, schools located within the Town's service area (two elementary, one middle school, one charter high school, and one proposed high school), residents of the Town of Holly Springs, and Town staff. 7.1.3. Target Pollutant Sources: The primary target will be sediment which has negative impacts to water quality as a result of increased runoff from development pollutant and debris transport, and streambank erosion and flooding. Other pollutants targeted will be nitrogen, phosphorus, and application of pesticides. Town of Holly Springs, North Carolina May 6, 20D4 NPDES Stormwater Permit Application 10 of 27 7.1.4. Outreach Program: The Town will develop and implement a public education and outreach plan within twelve (12) months from issuance of the NPDES permit. Our outreach strategy will include methods such as printed brochures, newspapers, the Green Plan„ stormwater information library, booths at local Town events, Town website, preconstruction and informational workshops and mass media to reach our target audiences. We expect to reach the bulk of our population as well as developers and others who do not reside within the limits of the Town. The above methods of outreach will provide individuals and households about the steps they can take to reduce stormwater pollution by promoting environmentally conscious daily activities such as, yard and vehicle maintenance activities to reduce loss of pollutants into the stormwater system. We also plan to inform individuals and groups on how to become involved in the storm water program with the tools listed above and the development of workshops, a business assistance program and an "adopt a stream program" 7.1.5. Decision Process: The Town will develop an annual education plan which will focus on citizen involvement and education. This plan will be submitted to the Town Board of Commissioners for approval each year via a Public Hearing and be open for public comments. 7.1.6. Evaluation: Evaluation of the program will be made annually and recommended changes will be made accordingly in the following year's education plan. 7.2. Public Involvement and Participation 7.2.1. BMP Summary Table: Appendix A 7.2.2. Target Audience: The target audiences for our public involvement program will be focused on all residents and stakeholders in the community. Information and programs will be designed to accommodate all ethnicities, economic groups, and people with varying abilities. We will actively involve all potentially affected stakeholder groups, including commercial and industrial businesses, trade associations, environmental groups, homeowners associations, and educational organizations among others. Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 11 of 27 7.2.3. Participation Programs: The Town of Holly Springs will meet the minimum requirement for public involvement; this permit application will be submitted for public hearing on April 20, 2004. The documents will be available for review. Staff will make a presentation to the Town Board and the general public summarizing the content of the permit, and public comments will be accepted. An education and outreach program will be developed within the first year in order to reach out and engage all economic and ethnic groups and provide opportunities for the public to participate in program development and implementation. We plan to incorporate all of the following BMPs (with measurable goals) within five years from the issuance of the NPDES Permit, as outlined in the BMP and Measurable Goals Table located in Appendix A, citizen representatives on a stormwater management committee, public hearings for all new ordinances and management plans, working with citizen volunteers willing to educate others about the program, and start or incorporate existing "adopt a stream" volunteer monitoring or stream clean-up activities in our Public Involvement Plan. 7.2.4. Decision Process: We will develop an annual Public Involvement Plan which will be submitted to the Town Board of Commissioners for approval each year via a Public Hearing and be open for public comments. 7.2.5. Evaluation: Evaluation of the program will be made annually and recommended changes will be made accordingly in the following year's Public Involvement Plan. 7.3. Illicit Discharge Detection and Elimination 7.3.1. BMP Summary Table: Appendix A Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 12 of 27 7.3.2. Storm Sewer System Map: We will develop a storm sewer map showing the location of all outfalls and the names and location of all receiving waters within five (5) years of the NPDES permit issuance. Information for the maps will be provided by historical as -built information, new as -built information provided by developers, and verification of the outfall locations. This information will be compiled through the development inspection process, field inspections, and incorporating it into our GIS/GPS utility mapping program. This map will be created and maintained within the Town of Holly Springs Department of Engineering. 7.3.3. Regulatory Mechanism: The Town will have to develop an ordinance, policies, and procedures to effectively prohibit illicit discharges into the MS4. This section of program development will be researched in the first two (2) years of the NPDES phase II program. Ordinance development, gaining legal authority will take place within year three (3) and implementation will take place within four (4) years from issuance of the NPDES permit. 7.3.4. Enforcement: The Town will design our illicit discharge ordinance to ensure appropriate enforcement procedures are in place and when implemented begins in year four (4). 7.3.5. Detection and Elimination: We will design a plan in year three (3) to detect and address illicit discharges to our system, including discharges from illegal dumping and spills. The development of the ordinance, policies, procedures, and standards will define non- stormwater discharges and the processes for correcting violations. In this plan we will employ Best Management Practices (BMPs) such as dry weather field screening for non -storm water flows and respond to citizen complaints. Other BMPs may be used such as field tests of selected chemical parameters as indicators of discharge sources, and on -site sewage disposal systems that flow into our storm drainage system. 7.3.5.1. Procedures for locating priority areas will be developed in year three (3). This will focus on areas with a higher likelihood of illicit connections (e.g., areas with older sanitary sewer lines or industrial activities). Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 13 of 27 7.3.5.2. Procedures for tracing the source of an illicit discharge, including the specific techniques we will use to detect the location of the source will be developed in year three (3). Illicit connections will be found through techniques such as citizen complaints, water quality testing, and/or visual field inspections (Dry weather (72 hours w/o rain) inspection performed at the outfall point) and the use of old building inspections and building permit applications to identify other potential sources for illicit discharge. Locating these connections will be aided by the storm sewer system map, to be completed in year five (5). Town staff (development and code enforcement inspectors, fire and police, public works and utilities etc.) will be cross trained to detect illicit discharges during their daily activities 7.3.5.3. Procedures for removing the source of the illicit discharge will be developed with the program in year three (3). The ordinance will also establish an enforcement process which will include Notice of Violation, corrective actions, fines and associated penalties. Our ordinance may be designed to provide a mechanism to require the landowner to correct the violation (at the property owners expense) within a specific period of time and the Town will continue with the enforcement process listed in the ordinance if the landowner does not meet the specific compliance timeframe allotted in the violation. The Town will incorporate the ability to repair and possibly charge the property owner for repair costs. The plan will also include internal procedures for spills within our own operations. 7.3.5.4. Once fully implemented the Town will annually evaluate the data obtained and the effectiveness of the plan to detect and eliminate illicit discharges. Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 14 of 27 7.3.6. Non-Stormwater Discharges: The following categories of non -storm water discharges or flows (i.e., illicit discharges) will be added in a program they are identified as significant contributors of pollutants to your small MS4: water line flushing, landscape irrigation, diverted stream flows, rising ground waters, uncontaminated ground water infiltration (as defined at 40 CFR §35.2005(20)), uncontaminated pumped ground water, discharges from potable water sources, foundation drains, air conditioning condensation, irrigation water, springs, water from crawl space pumps, footing drains, lawn watering, individual residential car washing, flows from riparian habitats and wetlands, dechlorinated swimming pool discharges, and street wash water (discharges or flows from fire fighting activities excluded) 1. Water line flushing: Allowable 2. Landscape irrigation: Allowable 3. Diverted stream flows: Allowable 4. Rising ground waters: Allowable 5. Uncontaminated ground water infiltration (as defined at 40 CFR §35.2005(20)): Allowable 6. Uncontaminated pumped ground water: Allowable 7. Discharges from potable water sources: Allowable 8. Foundation drains: Allowable (Unless found to exceed State standards) 9. Air conditioning condensation: Allowable (Unless found to exceed State standards) 10. Irrigation water: Allowable 11. Springs: Allowable 12. Water from crawl space pumps: Allowable (Unless found to exceed State standards) 13. Footing drains: Allowable 14. Lawn watering: Allowable 15. Individual residential car washing: Allowable 16. Flows from riparian habitats and wetlands: Allowable 17. Dechlorinated swimming pool discharges: Allowable 18. Street wash water: Allowable 7.3.7. Occasional incidental non -storm water discharges that will not be addressed as illicit discharges: These non -storm water discharges will be identified with the development of illicit discharge program in year three (3). The Town will document any local controls or conditions placed on the discharges in our SWIMP. We will include a provision Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 15 of 27 prohibiting any individual non -storm water discharge that is determined to be contributing significant amounts of pollutants to your MS4. 7.3.8. Outreach: The public and Town employees will be informed about the hazards of illicit connections and illegal dumping through the public education and outreach plan. The good housekeeping component will also train Town staff in identifying and eliminating illicit connections and discharges. 7.3.9. Decision Process: The development of a storm water illicit discharge detection and elimination program will go through the public hearing process and be consistent with the public involvement program. Items in this program will be included in the public education and outreach plan and utilize current Town programs. The overall illicit discharge detection and elimination program and the individual BMPs, measurable goals, outlined in the attached BMP and measurable goals table and be administered by the Director of Engineering or site specific Department Heads, 7.3.10, Evaluation: The program will be evaluated through the annual report and analysis of measurable goals recommended changes will be made accordingly in the following year's plan. 7.4. Construction Site Stormwater Runoff Control 7.4.1. BMP Summary Table: Appendix A 7.4.2. Regulatory Mechanism: We have an existing Sedimentation and Erosion Control, Stream and Wetlands Protection Land Disturbance Ordinance in place since November 1, 2000. Please Refer to Attachment 6. We have established requirements for construction site operators to implement appropriate erosion and sediment control best management practices via ordinances, construction standards and mandatory pre -construction conference which includes an environmental education section, Certificate of Compliance inspection, -will verify that the measures are installed as per the approved plan. The Town will develop additional requirements for construction site operators to control waste such as discarded building materials, Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 16 of 27 concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impacts to water quality. This will be added to the current ordinance by year two (2) and educate contractors of these reguTatlons through educational programs such as the Clear Water Contractor Program. 7.4.3. Plan Reviews: All development plans that have at least 20,000 square feet of disturbed area are reviewed for sedimentation and erosion control measures. Developers, or their consultants, submit an application identifying the Financially Responsible Parry and other pertinent project information, and pay associated fees for erosion control plan review with the first plan submittal. The plan is reviewed in the Construction Drawing review cycle, which includes a two week plan review turn around with comments issued at the end of the two week period. The plans are reviewed with the use of a erosion control plan review checklist which outlines standards that should appear on every erosion control plan and assist in the identification of problem areas. Erosion control devices from the clearing and grubbing stages of the project through the final grading are reviewed at this time. Potential water quality impacts are looked at during the plan review such as encroachment into floodplains, wetlands and riparian buffers. Staff requires the developer to provide information that the applicable permits associated with impacts to these areas have been obtained prior to the issuance of a Land Disturbance Permit. Once the plan is approved, or approved with conditions, a preconstruction meeting is held to go over site specific concerns, the towns ordinance, inspection, and enforcement procedures, as well as site specific critical areas that need to be protected throughout construction. Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 17 of 27 7.4.4. Enforcement: Once a Land Disturbance Permit is issued a Certificate of Compliance must be issued prior to starting clearing, grubbing and construction (installation of storm drainage water and sewer, curb & gutter etc.). If the site is in excess of 20,000 square feet of disturbed area and has not obtained Erosion Control Plan approval, Land Disturbance permit, or Certificate of Compliance prior to clearing and grubbing, a Notice of Violation is issued. If a site is not in compliance at any time through the construction process, a Notice of Violation can be issued. This violation can issued at the time of the violation or for not meeting compliance dates set forth in site inspection reports. Fines can be accessed up to $5,000 for the initial violation and each day the site is not in compliance with the ordinance. The Town also has the ability to hold building permits, inspections, and Certificates of Occupancy to assist in the enforcement of its ordinance. The ordinance also allows for criminal penalties for noncompliance. Projects disturbing less than 20,000 square feet are required to provide erosion control measures to keep sediment from leaving their site or entering waterbodies on the tract. If a site is found to be not in compliance with the ordinance, the Town will also seek corrective actions to bring the site back into compliance and assess penalties as needed. 7.4.5. Inspections: Site inspections are made on a regular basis (multiple times in a one month period) for all sites that have an open Land Disturbance Permit or Building Permit. The Town's Environmental Inspector, Development Inspectors, and Building Inspectors provide sedimentation and erosion control inspections for these sites. Inspection reports are written primarily by the Environmental Inspector for sites with open Land Disturbances Permits. Inspection reports list general site information such as project name and phase, location, weather, date, and Financial Responsible Party. It also includes if the site is under Notice of Violation, if it is compliance with the ordinance, what items are not in compliance, corrective actions needed, and specified timeframe for repairs. Upon the receipt of Citizen Complaints for possible violations of the Town's ordinance, the Environmental Inspector, or other trained engineering department staff, investigate the complaint, make field inspections, and provide necessary enforcement actions to resolve the violation and bring it into compliance. These complaints are logged on the citizen complain log and used to evaluate the program. Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 18 of 27 7.4.6. Public Information: Revisions to the ordinance are made through the Town's Public Hearing process. Education is directed specifically to many different stakeholders: design consultants, developers, home builders, contractors, residents, and Town staff. This information will be included in the public information plan. Currently the Town provides education to the stakeholders mentioned above by using various media. The Town has held one Clear Water Contractor Class with NC DENR Division of Land Resources, Land Quality Section, and provides education to the developers onsite during field inspections, during preconstruction meetings, with brochures and newspaper articles. Education for residents has been targeted with brochure information available at Town Hall, the Environmental booth at SeptemberFest, the Town website, and through local newspaper. Information used in this program will be included in the public education plan. 7.4.7. Decision Process: Any changes of the construction site stormwater runoff control program will include public involvement This is incorporated into the public involvement and participation component of the Town's Stormwater Management Plan including Public Hearings for ordinance revisions. 7.4.8. Evaluation: Monthly reports are made listing the amount of plans reviewed, plans approved, Land Disturbance Permits issued, Citizen Complaints, inspections and Notices of Violation. This information is then compiled in the Engineering Departments annual report. The use of this information Staff will review this information and make changes to the policies and procedures to ensure an effective program. The Town staff will also keep up to date of changes to the States Sedimentation and Erosion Control regulations and will revise the ordinance to be at least as restrictive as the states rules. 7.5. Post -Construction Storm Water Management in New Development and Redevelopment The Town of Holly Springs does not have a development standard that addresses stormwater management on new or redevelopment projects. The Town will develop, implement, and enforce a post -construction stormwater management program in New Development and Redevelopment including the adoption of a Post -Construction Ordinance and construction design standards consistent with the State's design manual within twelve (12) months from the issuance of the NPDES Permit to comply with the temporary rules that exist. However, in the event that these rules are altered, Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 19 of 27 we may consider changing our timeframe to comply with the new rules. The program will be designed to ensure that controls are in place that would prevent or minimize water quality impacts for projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale. We will implement strategies, which include a combination of structural, and/or non-structural best management practices (BMPs), appropriate for our community which will meet the state minimum criteria for BMP's and conform to the state's design manual. This could include polices and procedures to ensure adequate long-term operation and maintenance of BMPs this could include inspection, certification, and bonding requirements. The following information will explain how our proposed program will meet these requirements. 7.5.1. BMP Summary Table 7.5.2. Non -Structural BMPs: 7.5.2.1. The Town's Unified Development Ordinance, Sedimentation and Erosion Control, Stream and Wetlands Protection, Land Disturbance Ordinance, Flood Damage Prevention Ordinance, Land Use Plan, and Open Space Plan currently provide requirements and standards to direct growth to identified areas, protect sensitive areas such as wetlands and riparian areas, maintain and/or increase open space and provide buffers along sensitive water bodies, minimize impervious surfaces, and minimize disturbance of soils and vegetation. These ordinances will be revised accordingly to meet the State's minimum requirements. 7.5.2.2. The Unified Development Ordinance provides for development incentives that can encourage various types of development. Additional incentives can be developed to promote infill development in higher density urban areas, and areas with existing storm sewer infrastructure. 7.5.2.3. Education programs for developers and the public about project designs that minimize water quality impacts such as the use of brochures, preconstruction meetings, informational meetings, newspaper, and the Town's website. These tools and others will be incorporated in the public education portion of the Stormwater Management Plan that Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 20 of 27 focuses on the post -construction stormwater management program in New Development and Redevelopment. 7.5.2.4. Other measures such as minimization of the percentage of impervious area after development, use of measures to minimize directly connected impervious areas, and source control measures often thought of as good housekeeping, preventive maintenance and spill prevention will be incorporated into the post -construction stormwater program. 7.5.3. Structural BMPs: 7.5.3.1. Currently storage practices such as wet ponds and extended -detention outlet structures are required on sites that have known drainage or flooding problems. The use and requirements for these practices will be incorporated into the Town's Engineering Design Standards and Specifications to meet the state minimum requirements. 7.5.3.2. Filtration practices such as grassed swales, bioretention cells, sand filters, and filter strips are currently used in areas adjacent to riparian buffers. The use and requirements for these practices will be incorporated into the Town's Engineering Design Standards and Specifications to meet the state minimum requirements. 7.5.3.3. The use and requirements for Infiltration practices such as infiltration basins and infiltration trenches will be incorporated into the Town's Engineering Design Standards and Specifications to meet the state minimum requirements. Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 21 of 27 7.5.4. Regulatory Mechanism: The Town will develop, implement, and enforce a post -construction stormwater management for New Development and Redevelopment including the adoption of a Post - Construction Ordinance and construction design standards consistent with the State's design manual within twelve (12) months from. the issuance -of the NPDES Permit to comply with the temporary rules that exist. However, in the event that these rules are altered we may consider changing our timeframe to comply with the new rules. 7.5.5. Operation and Maintenance: We will develop policies and procedures to ensure the long-term operation and maintenance (0&M) of our BMPs and will be consistent with state regulations. 7.5.6. Decision Process: The decision process for the development of a post -construction storm water management program will go through the Town's public hearing process. The town will hold public information and comment meetings prior to the public hearing to incorporate comments into the final plan while meeting the minimum state requirements. The post -construction storm water management program and the individual BMPs, measurable goals, and responsible persons for your program will be consistent with the attached BMP and measurable goals table and be administered by the Director of Engineering. 7.5.6.1. Our program will address storm water runoff from new development and redevelopment projects to meet the minimum state standards. 7.5.6.2. Our program will be specifically tailored for our local community, minimize water quality impacts, and attempt to maintain pre -development runoff conditions to meet minimum state standards and while fitting into the Town's existing comprehensive and long range plans. 7.5.7. Evaluation: Monthly records of plan reviews, permits issued, citizen complaints and enforcement actions will be compiled into an annual report and reviewed. Evaluation of the program will be made annually and recommended changes will be made accordingly. 7.6. Pollution Prevention/Good Housekeeping for Municipal Operations 7.6.1. BMP Summary Table: Appendix A Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 22 of 27 7.6.2. Affected Operations: A complete inventory of facilities that will be evaluated through an environmental audit to determine the potential pollution contributions as required by the Municipal Industrial Activities Permit will be completed in year one (1) to define the municipal operations that are impacted by this operation and maintenance program. A list will be compiled in year one (1) to include all in=trial facilities the Town_ owns_or operates that are _,subject to NPDES Stormwater General. Permits or individual NPDES perm) s or discharges of storm waffer assoeiated -wif�i iridustrial -- __ - t activity that ultlmate�discharge to into our M_S4. Asa part of the C In_dustfral-Ac6Mties perml& ap 1p Ip cation, we will assess municipal o facilities owned_by_the Town for potential pollutant contributors. A S stormwater pollution prevention plan will be established for each U facility that has been identified as a potential pollution contributor. Each plan will include BMPs that target the identified pollutant. All other requirements under the Municipal Industrial Activities permit will be met for each identified Town Facility. Operations may be affected by this measure but not limited to would include maintenance yards, parks maintenance, vehicle equipment maintenance, drainage system maintenance, storage facilities, street sweeping, ground maintenance and chemical applications. 7.6.3. Training: Beginning in year one (1) the Town will enroll staff in any available government employee training programs available through NC DENR, NC State University, NC League of Municipalities or other available resources that focus on use to prevent and reduce storm water pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and storm water system maintenance with funds that are available for training in the approved fiscal budget. The Town will compile a library of training materials on pollution prevention for public facilities using existing materials gathered from other organizations or creating new tools as needed. Training of staff will be included in the public education and outreach plan in year one (1). Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 23 of 27 7.6.4. Maintenance and Inspections: In year one (1) a maintenance, inspection and training plan will be developed to reduce floatables and other pollutants to our MS4. Implement the plan completely by year three (3) and incorporate training into the education and outreach plan. We currently have an existing drainage maintenance program that is designed to remove floatables and sediment from the storm sewer system located in the Town's right-of-way on an as needed basis. The Town will research potential funding sources such as a Stormwater Utility to further develop this drainage and maintenance program. 7.6.5. Vehicular Operations: An inspection of municipal parking lots, maintenance and storage yards, waste transfer stations, fleet or maintenance shops with outdoor storage areas, and salt/sand storage locations, and snow disposal areas the Town operates will have potential BMP areas identified for reducing or eliminating the discharge of pollutants. This will be included in the environmental vaudit and necessary actions to come into compliance with State regulations will be made with the completion of the Municipal Industrial Activities Permit. 7.6.6. Waste Disposal: Waste is collected and deposited in an approved land fill, evaluation of collection procedures will begin in year three (3). 7.6.7. Flood Management Projects: The Town will incorporate BMPs in the design for Town projects to be utilized according to the site conditions. This may include structural or non-structural practices designed to reduce pollutant loading in to the stream as outlined in the approved post -construction stormwater management program for the Town. This will begin in year one (1) in areas where known flooding problems occur. This will be expanded to include all Town projects within five (5) years from issuance of the NPDES permit. 7.6.8. Existing ordinances: Existing ordinances will be reviewed through the development of our stormwater management program starting in year (1). Revisions to the ordinances will be made to meet the states minimum requirements and new ordinances will be created as needed. Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 24 of 27 7.6.9. Other evaluations: Other procedures to evaluate spill response, oil recycling program, maintenance of hazardous chemical inventory, sanitary sewer supply and maintenance programs, and the evaluation of road construction and maintenance procedures will begin in year three (3). 7.6.10. Decision Process: The decision process for the development of a pollution prevention/good housekeeping program for municipal operations will be made through the Public Hearing process this program will incorporate individual BMPs, measurable goals, and responsible persons for our program as outlined in the BMP and measurable goals table and meet state minimum requirements. 7.6.11. Evaluation: Evaluation of the program will be made annually and recommended changes will be made accordingly in the following year's Good Housekeeping and Pollution Prevention Plan. Town of Holly Springs, North Carolina May 6, 2004 NPDES Stormwater Permit Application 25 of 27 Appendix: A. BMPs and Measurable Goals Table Town of Holly Springs, North Carolina May 6, 2004 NPDES Storrnwater Permit Application 26 of 27 O. N L O m a0+ c O L V A Lu 7 O M c m V 3 V W V m 7 a L w d � a E� (A � R � L d h m m d V e1pi R ga cc(A c x L Fn c m m a f0 y aIL P co c1. 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