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.
CO
o cn
Cl)
co ?
cn
g C
o
C
€'
o
o€
w
N
c c
C
p
C
O
y
O
" o
c
E
c o
2.2
C
o f
w
aw
c
w
as
wrL=
ow
M
X
X
X
X
X
04
d
X
X
X
X
X
N
AM
X
X
X
X
X
oN
X
X
X
X
LO
N
N
X
X
X
X
c
'Occ
m e
E
CR
o
m m
o
om Q�R��Rc
0= v 3 c�v
o'
L� m
Sv
(N6 0 o=.4
_w.
0 (� 0
Oyv i
N
R Q N R [.t
E
C O C
= 'm
N' U w c Ln
a> 0
o c
N N
2 �p
l6 O `
sla'e o'
tll
m
>um
3 E_ c
`o•pyER3rnmoo
R
N 3 E .R m 0v
maywda+'Lr
d� o c coi
�c
oVvp
I .c
(� �
O
L O C O
.0 y U A
dCO
W GS
vRoa��
R R
y W L� lO R
dyai0ca:Q�c
PD a
hod
d €00E�`�c
c3
N t R
CO a. �+ 'p N
E •= .�_
o' o O O
`
�C
CL
C C
N +a' C 3
N
a y
d N >. N
Q�1 (Op
i C y E N
L
Ryay�yR�0a'-'om°=L'as
pp
3ipp°��rn�c°n°>L°aoaE
N
nt N 2
R p d M
3�.c
c N 3 R O
n o O N E
u
U d
�
c� c
E o '� •�
3 € 0
o Si 42 =
c R� y�o:g
o �- c
9 a f0 i
=cE'na
mPoR n
oa�ioE
yr
`�a�g
.S
jaw oc i
..�0�... o
E c rn �' y
S `� y.m
R=
N C Y
cmR
R C O c !6 .R.
C~ V
C O
C,
g
0E
n.Opc�cc��mm9o�LmaaQcEi-
gcn€��;§=ate
o
cocQo,=a�E'a4io`0-
5
c
12 € v n
_ E-
i L- a;
o �= R L
c c --
m 0 =W
a R c c
N d� N C.
rnQ c y y
� N�-
CL
21 IL
a
C
t
cu
dS- %.
c E
1
:Ea
CO
�'
e
o
�„
�, SR
Q
O
€.0
N
N�
O N
(Z
hC-I 1-C-1
0
Z
QpR1
N
N
Ln g
N
F
5
V5
UyN
2
2
2
W
e
w
w
W
x
x
x
x
x
x
x
x
x
x
x
x
C R
O O TL
U N L
O C
n m
o) . c E
N c N w
m._ p FL -
O O
w m CON 2
m (D-
m € -
_o_oR
c
oP_
vi
o
~CuiPiE
-E.cCm
�.-.
@NE
L.
LDa
CL
Cut
O tca
C N'
C m C O m C
O N
f6 O O C-
'r N
y .0
C m N
N
C
Lm
R
N O w 3 (n
�L'p,'S 3 3
U C O O
'O.' W tNJ (=d G
Lj
d N
p�
" `m 3 C C
d m N
H C
U
nm
CD
o
cp�
y o v
o o
Ol n t+1
�° c o •..o� m
C m Y (D N
N (C6 T.0
E p WQ
C
MWO
•3
cco
o. o
coo c
n a co y
'i'v - E a
a �,- L� c a,'
n§ m Pi{'la
m e r. E c
oa��-�
��c�Y�m
ip n m
og=
�=
wp� �
m
v
ce aci v
o
�i
w
a
•O C
g. w
N
a.R frm, fed
O m m
O N n
U c N
C
d
y
N
w
8ti '
a
ca
Y
9
7
U N
C
O
N
a
W d
m
O
�o
OD
rn
14
C
2
41
a
R
O.
co
d
8
7
a
Lm
w
_N
C7
m
a
V
7
H
af0i
V
C
m
FA
00
eV
li
ti�N
m
�@
w
W
`o
e
L
2.c n
�w C
0 0 L
C
L
C
W
C
W
C
W
5-
lL_
•c •>
6� W
•�
W
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
q�}; c6..
Q..
N
M; O
L
p yL� W
O c c C m N
pT
m of ; di
c D V
v E�A
c m O R
m o' y�
o$ E c"
a E
m
v" _•
`_.$
N ?
0 my
c
c 3 E'E
f65
E c ".
f0 o..
O U J
m
QQ�
C Y N C
%.m 14
° E Er to c
,.�.
L V N
8��c€�
m p
E
�9 L L
8 C*,�
m� 2
CL a' m m N
m•� c c
T
me m vS 3
g-
8
mom
c pE � o 6
Cp
N `o o E-e (D
cb •....
2 a =--
2
E o'.o-
Y,n E_c D
O
m 8 0- C
"�jj N N G
"-
W (p
E U C L t
.t... p
L �L
N
•O (J
n .X
N m o
3
O
m E� a E
ci
d� o o
c '� `O
m N
w of
N
�.0.a o.
w
C
TR
Q pp@� (a� �
O`
p)
v o —
S E O Cmt '` N
m'8 E o
N 1 "•'
/ 'Q
O f0 L"
Qc a�
E m 3.75
C O
[6 g Q E
m f0 .Y3
O_ m L
T Lm F
N `�- N E L
N C O E Y
+m� m C
0 R N
d N m m
Q N T •O p
•>
N N c m
�_ a O 'O
'
C N C
j l
= L •ram
N m '=
U M y E C
O E N O' L�j
=; (o T
N
Y C U
3 E a `P'i
Ln 3
I W �
�
K OO_ t0
c m L E p
O c 12
(6 G
3i� � c m "N' ,N
a m o ur [q
8 r0.. _P' �
c'7 .N_. O m y c
01 N y
m
€ o, a
€ O c y—
O 3
c c a (D ._
$ L
N
F- 3 m m? 'L)
6Luva
49 E€ E�
a 0>p0FF3
m
ami E' Z �'
m'in_$ av
m m E c
y�-+
LF� P
N
LLaa
h O
N C_ •- �' N
c0E00
N •lp N
00 ,CCU
"'� 0 'C, N
C
O R
2
L O
N f6 _C
R 3 O
U C
N O U E 0
Of N L•
C T a
m R E U
0
N�
��
c m d
O
C N
N �2 TC
w
r pp� V
N 8 2,2 CLZ
...
C .- ` tll
L U C O_w
Lam'
� 16- C'O
m r�
T- �
d i
� � m j
amWca,cLcmUG8m
�wtgwE�immc$omEn.c_.c_�L
E
\
y f
0)
p
N
C
H
m r
`�
U
N
E'er'
u Y
m
m
Q C01
y
(A
Z
m
a
E'D
a�qte°
Ec
y
CL
S
cyncyn
W a
vL
+�
V
o
VI
O S
M
d' in
kO
g
N
r
N
a
H
y
R
0
d
a
m
H
N
fa
R c
Ub c
a o,
E a
ma
c
Y
d
n Q
y� D a�
= O_= C
Q
rnt cE
C) m m
0 y 3
a_EiFo-
n nv
a E m
b e
Je
N 'C
N
E 2
n
rnr oa
rn�i>d
cd o v S
c
0
Y
R
V
c
1}m
W
d
N
LM
Z
U
Yl
G
M
L
w
FA
m
0
C7
d
a
m
3
y
v
V
c
m
m
d
d
AR
R
°�
N
N. r
o c
ig
�
+�+
E
E �
E
E
p
_
`o_2a
E
Q
a
W
(DC�
€
cnWw
W
w
o>..in
X
x
x
x
N
co
N
�, v
x
x
x
x
o
M
X
X
X
N
o
N
X
X
N
g
.�
x
N
C N
O
0
(D
T
9 'C
N
0
� C o
Z a M L
a3 m>
L n c
> C
c m c o 0
c42m
"n.«E
3m
asLoasa"O
CNN—GaEa'E'3,
w
m C
N
U1
0 o E:a
�T
—1Na��
.—
�,
N •� '— J C V
S
c W S
�
8pr.
C o C '''pppry
V
'C OE j
Vj
>2 'o R
2
$y � C1 C
41
aa)coviv
Coco E'S
i'I'o
`o c
$�
CO
ash
o
E0 `°
€ 5 cci rnC� c
c
m gr
�_ `° c 0
FA
v9 v,
C U
L cC� R
cc
E ov
g"c
C_ a
O S T V C y C
pp� nFnFff
C= c
c o E%=
•� as c c
C F
:a x
W
a� t m
Q NSA
��°��coX2cno��y�L1
O C y0
m d •mo.. y O N
1O o. Ca
d
n'
S
'EL
L of
N a) € F a) C a5
1w]
`
N c tr
>
2 C
N ..o. d aI
nE o5
U N
oU' LC]vw
u1 t «�
yr
yr
W
E
N
a
Y _
a
m
rn
0
m
+S;
0
3
aa?L (
m
o
E
Y
ns
m
a
o >
a'4
E
a
J
U1 H
0
V
i
N
M
d
m
w
a
Z
9
v
s
0
E
E
�r
m
m
00
EB
4
d 0
a
E� �n
nE 'aa
m E
=
-NN
NlUc
N6
Ti
U
co
E
C.lN�6'
I
o
c
W
c
w
c
W
W
>
LL) W
X
X
X
x
X
X
X
X
X
X
X
X
X
X
o m
c
O a
c R
w e m
(D P3 `o
c o
-
E CO
E
.EDto
c> m
? - C
m c
N (6
o€ a
w O w
;n p
.�,
c c v w
O O
w
U j
Gq d CQ E
N E N
€ C €)
t�
p.
N
a)O C:
O .... C
C t H`
f-
C E r N
(6 C
LD
V N
N
C pO' U
C
C?
U C
LN C
.p..
ai=,
O 11 R
d
�y
E dC+
ACL
dL
•py C C N'
01
C C E
N
'D N N! O'
_
y pUU (p� L
G-
�_ .0 a
O
(�
E 2
C
C S C
C C C {Q�
�j• O
O
`p
L y N N
E 3 o
CO C N
"C
Z; d S
N m e W
N
O
`
t
m
C v vdi a,
cCcqc�
o'-�°
cc( iF'aa>E'va)
Ic C Y60
p N p.9 'C
N L m
.r=.E
pONj9pC
wC
_
�
N
(
jC42
`n0oa9
O
WC�
�C 9 9
�'COU
c_c
pco-c
d)
ca�
o8
Ec
d-
5o
J
d
�mCCO
16
m8.ogt
v
�Ncn6
o
mZ
8 E
m 'L cE
w
a
m.d
cv
ow,Ec�;=cdN a
E cm
uao
�rcC
mv�
.,'.
0'
F..p
nl
c—'1c
��'�c
'
i�>Qcp
ao
Po=�
:�C
'Q
O p
0
m
aEi
i
a
A
cn
C
O
o I
Q
m 3�
g
m
In in
_
Ln
`=
c
A
d
m
N
N
N
N
aj
m
as
l6
V
a
(O
c?
a
U
d
t6
U
n
-
N
-
lV
N�
U)
U)
G
C
G
Li 0
N
m
N C
E
N
E
O)
N C
N
C
N
d-
E
o
W
2 o
2
E W
o `o-
E
0
E
0
�C
c
E
W
Wow
wco
W
w
o
Ln
x
x
x
X
x
x
CO
N
et
X
X
X
X
X
X
ti
g
M
x
X
X
x
X
X
to
a
N
X
X
X
X
X
X
LO
o
x
x
x
x
X
x
N
C
N
O
•� 0
O T N
Of
�
0.
_t
E
pc S>, o
g
N
E
O O
co :2N
O a'
.3 N
3
J
c c
us
o
5r000 3:w=
�
c$
N
of
maci,iriL
EoiE
o�
no
w
(4
Q^ N
C
y` w. y
p O p N f6 r
.;
€ RS
O
- L NG.^i'N`
C
} N O C V Co ••'�••
o mN
_m (y6
0"0
'ate
o c E.
d
€ m e-O
m 0 2 L'
vv11
o
d
ymo
5
�'oao0
t
rn
3: —2
O w N
9
L
L
h
o,i C C e
C C .O
W
c
R2`EOmmS
L'
rnccm
'a a
�
U"O 3' Ma (D �
� rn � > N
'm
o a�i `o
v 2fm
C
dZa c a0
7 C c > >., f0
n� ma acid
ari
OL
m 3
ID
R E
E�
E.
0
o E E
o E
EI
fo
(D0 CD Mpv
ci'
4
a m
'Q
N O U
.o
N 0
> v�
Y N d C€
n �Lv.c
N� (O C
>w N.c c €
C
�.,3.,
!6
aw
m�
v m co 'v�i v
N a m=
aEi
aci 3
.`
O
w
C
+'
N
y
€
01 G7
CL
dcm
IzzC
00
c
c
m
0
m
U)w
o
y2
J
m
C]
d
ZFF
V)
d�
.--I
N
M
ct
Ln
t0
N E2;
N
N e
N
yy
.m
N
co
0)Em
mE
a�
wow
w$'
w
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
(D
_
CC O O -8
C
—
C O C c=
N a O
J
O
y
SC .S c Ln C
O O O y Lu
to
0
E
R E
m� E mi-�i
c go
c 2
E
N
_m m m E
rn rn 3 w
R�
O'
i
v O C N
N n
c o. `Z c
V C R (6 W O
Z
z�
O�
m vi
N > R' wN
O)
o N
'n
j '� c d c FL
a -NUU C� O
'.t= N E Z 'j
co
C
N
L r�
C N C
N N
i 1 0 N E y
-O .,Op
O
W = C
E G 0 t0
Q
C —
'O
T (n CTU n6
M '45 L
O ry
C
•-
A4� T
E U�y?j' m
C
U Z O '� O
c W -� 79
co
�
4�a
SCL
2�oc
L,E
�Q
:o N-L
c o G
m 2 mE E `� O m
o QQ`��
iO
2�
�gc
�� p
TCC Cp
2@
O
_C R 2 V_ y �p
C
0;
CoN
((pp
N J Y C>
C
LMyC 2
pp
LO OZ. Ey 1w
�'Q O
U C
w E C
Gj O C
N C w O p� N
NOOm-a
Ory
N
KCO"
1%
M m aC a
wo
a�m
C
? N�
0
Q oJ-yp
��c
a
nwim¢Q
a WU"O a)
E
CO
m
O
R
N
i
c
$
o
I
a
C
O
�
�
�
N
a
ja
�
C
�
N
H
U
N
00
C,
CD
a �w
}[
N
a+
4C C
C
E
a
O
�o
a
0
d
N
}
X
d
Z
CD
CD
X
C
N
o
M
X
y
E
4)
Im
Elk
c)
>. N
X
R
CN
c
g
N
m
O
w
p
C
N
O
CL E
3
`o
NID
V
_O
3
C
L
O
E2
m
is
C
0
`
3
S
E
�
B
3
g
LL
q
O
a
O
'�
c
O
qW
S
1'
a
L
m
Z p
o
L
Bw o
3
>
y
c
N *
M iF F 2
N
Nf2
N
E2
N
N
•y/LJ
i.
•�
d
�N?
CO
y U3
CL
E fq
C7
to
CO
(n
Ul
[7
fA
-Po
C
W C O C
.�C
.� C
rmC
..0
-P -
.0 C
a)
EWE
ID
46 E
EE
W
:E
E
Q
oZoe
2
w'c
Q oc
'i
W
'c 'S
W
>
W
W
W
>
W
W
W W
S
W W
ICI)
O
LLI
O
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
X
_
—
~ N
LL
m
w
F�F
0
.
N'
C— a1 O
C
�� t6
C
N U .0
O C
cg' ;
m
�_ C
d
N
N 3 8 :5 m 0
N C_ C�
T_
I- R
c N
a..
o
$ dW 0
4
C O
��
V �j x 0 0>
6E a'cco
LL C
�Pi�ca
M 0 0
'V;
0 a:
O
`0
,QO-5;
CV C
N
:O
(D
UU c a 'g
N N Z .�
U
U1
c? c 3 a
c 0 rj. O O
m O C
d 0
c>6 N d'
E—_
N�
c N
O
m
n.4)9
av
�-Eic
n�0"E2c€a�L
NCb]j.
tO�
O
j C N
O
(6 C O
d a m
O N O
FF;cas
C,
po
._
w
O
E
w
3 l6 ad
C
VD
w C
N O wO- `
C
f6 g
C �j
N t$�U 8 _N _O p�
N E C
-O O
N U1
�.
G
N
N
�¢1N
RR
C-N N
N
y p
p-Ct,�e' C
N
N R�
$QL1 N
Cl)
y 3 N
C0
f6 �+ f6
t
U '00
'y r5
-�-) p
O N N
�j
cL
0
.o
$ !c
po., c
t�t,
E$
c
v
C N
�j
�F
O
c o
O fE�
�p m
N
O.
Z
N
C
t"/�'
3
N 3 G/2jj
N
O C
N 0 C O- N
O. (6
cam. i{ N Cj
O O
C
C ;p
d
N
Uo a
N C
p N "4"f
C N
CJ j c
O
C; ,2
U
{Q�
y
N N O
O m
3
$OU
N FS
ca C
O N O C
m2v-io>0'0°
N N
Q
E N E O
°'�_ornEE.-
pNO
Or. d G a)
U �N,
""
N
_f63
m C>>
0-
N N
3 Q
Y N N C
L C
y N N
d
E
E
8
E CC
N Ep o
(�
Cj
o p Cp fJ pCp
C
�n
N i
C
O
N c l6 N n
N
p C O
lU L
t :C
N
(� Q
>
..0.
�
c� N
cii V
2 O U
V /0
H l6 m O fn C
Ci N 3:
Q N 3¢
d LL
N
rUP
c
rn
c
E
ai
rn
+off
ate-+ O
CO
C_:
c ;.
_
u
3
E
�3
c
3
C
L°
3 fa
a
a
E
0.'@
o
V
}
d
CL
_
3
L.
m
C
a
Pi
S
m
H
Mm
m
a`
N
M
N
%
n
GD
01
O14
E
3
F
N
m
00
fl
L a
f0 �
fA C
CL
m Q
H
i
a
O
m
a
'U
C
i
w
ch
C
c
4)
E N
o O
0
O
`w C
E O
E C
E
h C.
N C
w O
m O
O
m a
Cie
-2 LL
� a
2 Q
s LU
W
m
m Q
u W
a
Z
E a
m
If t0
K
m
49
c�
d
mca
R V
m 0
C
o
E
tll
p
c
o R
Si co
C R 2
a
waso
was is
w
N
X
X
X
SPa
X
X
X
CD C)
M
X
X04
X
i� N
X
XCIA
X
X
N
X
N
^`
ERE -0.
O) C)
g
a`�ccpOc
L G
�
_ = �,g m
Ca W
ahr -
E � E m c
ie
C IOU''Npp
R g" W g
49 L O j
00 N N ccN
y�y
O m
14
U
N N E
C
m e O ep
cc
c
R AS$
R�m_�i�
cNmc��
LLDrr
07
4c
s 3 od78Ea)
w-5°> �E'�
-9
Rd� €
U.
f-...�` m0-L`.3
csE,}QE'_3=RLt0 yyoE`��W
3'�fnc
O C
"20
S C
lQ
pL c E m Q
aci o m x m 2 `°
c
78
g` E
E�Si"� c
=CLaRic�
R>m CLI EEw0
c co
c-in•.-.
R C O C N
m��
coa�E w�E
._ C R 0 C "0 E
��m�i5�"o
—_ m L 0" 0 0
�'-
cL E
R E 3 E nc c
E m :: Ev nryE
cL ro m� Epy�g
m.� 3='gam E
ca
� a
0
� •E
r,
fi
c
d
_
Q
1
O
49
N
E
C
C u
C
O
0
C
W
H
p�
t
% i*E
C
a
a
N
N
N
(D
N
0
@
U U
0. 9
ca
(D N
D=
na
d
0 o
w 2
U
U =
U N
a, C
d
tqE
Oo
8 of
)E
�' C
C � m
U 5
.mN C Y @
C .2 @
-S .0. a5
� .�n
W
n�in
W.6 0
o_
W 0
(n�
LLI
ca 0
0 0
06
.6
X
x
x
x
x
x
x
x
x
x
x
x
x
x
x
N
�O N LD
Ea
N
�n°L c
CY
c
SN w
_f
8
NOCa
E
.cR
O
moc
o
mc
$O..
U(D
.0
(D N
L N O
'JO
C N
N E n O (0 E
O
y C
E Y'
N
@, O T N
N N a7 N$
O
L C N
N m
(6
N
a5 C m a@. C
N
U a1-...
C@ N
O
m 2 C �'
E
a
C
>>
p 2 a)
@ N E U
3
E y
n
c'� Y° c c
m «pp? c y
yNm
m `o
E N c aa)i
=NN'OC
(0- N
M�@.
'�aC@
E O
JCO.�N�
pN`�
OT
NCOLN
L
{`p
CO T V
(D E
�C
EL 0
.
Oa�U ;U
0
-
j
O
O�
�
O
N—
<6
@
p
n
p' C
OE'
J y
C
C@ U N C
o @
-E N
@
01 J L
m e
@ N
bi o. E m
SC
S
N
m c_
N@
C
E
N 01678
oo
m o
@: in� m
c�pY�i
U 2$ n c
o�L
a$i
'f�_$/l
m
w ac
c
$ C
N G
.Q'
N J
C
-9 C
n
0' C 'E N
O0
... €N
N@
(C(pp
E 2' U O
N
@ @@ U O
N L
aEi E
O@ 0
N
E v
.> m
-� @ o
a E U U1 �O
N$
'N n
T K
E �°
N J E
d M
2 w L++ a
rt
.O �. N L' Q
N
'X E Q>
> .92
U@
Co
)OUi
o m
d R
Nm
a� n
pp$
E@N
yyp y o
o �+
'QQ� y $ w?
as 3 w m�'
O_NV
a�
@ `m
@2C@pa)
,`�_'
Sri
N
>
N
N
C
U w w
Q N
2 N
W a C in Q
o 2
W N
T
U
ca w
d
C
n
d
C
7
C@ i
O
CQ.
O
u
aj @@
> $
N U
E
N
L
@ N a+
O
N
Co
N
V
7
o
72
@
a
m E m
g'o
(u
o
L a) @
@
'@
p
'O_ i
d�j
u C
V@
7 0
N
m
C
C
L
a)
N ,�
y t�
7
7 U a@.'
Cfpp
C 7
C C
N 7 O
LL
N
n
>
W
j y f
W i (n
@>
E al
@@>
E
C
N
Q
Ln
lO
k
€.