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HomeMy WebLinkAboutNCS000436_APPLICATION_20040429STORMWATER DIVISION CODING SHEET M54 PERMITS PERMIT NO. � rc9 � '"l,3 C� DOC TYPE ❑FINAL PERMIT ❑ ANNUAL REPORT f5—APPLICATION ❑ COMPLIANCE ❑ OTHER DOC DATE ❑ ��� � �� YYYYMMDD State of North Carolina Department of Environment & Natural Resources Division of Water Quality OFFIC USE ONLY Date Rec'd v s �aoy Fee Paid 7. . Di) Permit Number jC g 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 NPDES Small MS4 Stornnwater Permit Application (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 Seeking Davidson County and the City of Lexington _ Permit Coverage b. Ownership Status (federal, state, Local' or local) c. 'Type of Public Entity (city, County and City town, county, prison, school, etc.) , d. Federal Standard Industrial SIC 91 - 97 Classification Code c. County(s) Davidson County f. Jurisdictional Area (square The County does not own or operate an MS4. miles) The MS4 for the City of Lexington covers approximately 17.6 square miles. g. Population Permanent Davidson County 2000 Census �- 147,246 City of Lexin 7ton 2000 Census — 19,953 Seasonal (if available) NA h. Ten-year Growth Rate County Annualized Growth Rate — 1.52 City Annualized Growth Rate — 1.87 i. Located on Indian Lands? ❑ Yes ®No 11, RPE / MS4 SYSTEM INFORMATION a. Storm Sewer Service Area (square miles) 17.6 square miles b. River Basin(s) Yadkin River c. Number of Primary Receiving Streams 7 d. Estimated percentage of jurisdictional area containin the following four land use activities: • Residential 67.5% • Commercial 13.5%n • Industrial 11.7% • Open Space 7.3%n Total = 100% e. Are there significant water quality issues listed in the attached application report?_ ® Yes ❑ No Two streams are listed as impaired based on the Yadkin -Pee Dee River Basinwide Water Quality Plan by DENR-DWQ. Page 1 SWU-264-103102 NPDES RPE Stormwater Permit Application II1. 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 IV. CO -PERMIT APPLICATION STATUS INFORMATION (Complete this section only if co -permitting) a. Do you intend to co -permit with a ❑Yes ®No permitted Phase I entity'? b. If so, provide the name and permit number of that entity: • Name of Phase I MS4 • NPDES Permit Number c. Do you intend to co -permit with ® Yes ❑ No another Phase It entity? d. If so, provide the name(s) of the entity: Davidson County and the City of Lexington 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 your ermit obli rations? ® Yes ❑ No b. If yes, identify each entity and the element they will be implementing • Name of Entity NCDENR Division of Land Quality • Element they will implement Construction Site Runoff • Contact Person Gray Hauser, PE • Contact Address 1601 Mail Service Center, Raleigh, NC 27699 • Contact Telephone Number 919-733-4574 c. Are legal agreements in place to establish responsibilities'? ❑ yes ® No V1. DELEGATION OF AUTHORITY (OPTIONAL) — Not Applicable 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 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 nay direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the .system, or those persons directly responsible for gathering the information, the information .submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. n �ti Signature / V Name Robpft Hyatt Title County Manager Street Address 913 Greensboro Street PO Box City Lexington State NC Zip 27292 Telephone 336-242-2200 Fax 336-248-8440 E-Mail rhyatt@co.davidson.nc.us 1 certify, under penalty of law, that this document and all attachments were prepared larder my direction or supervision in accordance with a .system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1 ant aware that there are significant penalties for .submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature Name hn Gray Title City Manager Street Address 28 West Center Street PO Box City Lexington State NC Zip 27292 Telephone 336-248-3910 Fax 336-243-7371 E-Mail iohngray@lexingtonnc.net lexingtonnc.net Page 3 SWU-264-103102 NPDES RPE Stormwater Permit Application VII1. 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 Bill Clutter b. Title County Public Works Director c. Street Address 913 Greensboro Street d. PO Box C. City Lexington f. State NC g. Zip 27292 h. Telephone Number 336-242-2007 i. Fax Number 336-242-1203 j. E-Mail Address wclutter@co.davidson.nc.us a. Name of Contact Person Rick Austin, PE b. Title City Public Works Director c. Street Address 711 Talbert Street d. PO Box C. City Lexington f. State NC g. Zip 27292 h. Telephone Number 336-248-3930 i. Fax Number 336-249-3584 j. E-Mail Address ricka@lexingtonnc.net Page 4 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 NIA Management Program NIA b. UIC program under SDWA NCO055786 Lexington Wastewater Treatment Plant NCO028037 Lexington Water Treatment Plant c. NPDES Wastewater Discharge Permit Number Roger Spach, City Superintendent of Water Resources 711 Talbert Street Lexin ton, NC 27292 d. Prevention of Significant NIA Deterioration (PSD) Program NIA e. Non Attainment Program f. National Emission Standards for NIA Hazardous Pollutants (NESHAPS) reconstruction approval g. Ocean dumping permits under the NIA Marine Protection Research and Sanctuaries Act h. Dredge or fill permits under section NIA 404 of CWA Page 5 SWU-264-103102 NPDES RPE Stormwater Permit Application 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-268). 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 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 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 6 SWU-264-103102 O�O� W A r�RpG Michael F. Easley Governor rWilliam G. Ress Jr., Secretary North Carolina Department of Environment and Natural Resources (D Alan W. Klimek, 11,1 E. Director Division of Water Quality June 1, 2004 Ms. Jane Kiker Davidson County Finance Dept. P.O. Box 1067 Lexington, NC 27293 Subject: Incorrect Check Amount Davidson County and City of Lexington MS4 Application Davidson County Dear Ms. Kiker: Your application fee was received on May 25, 2004, however it was in the amount of $750.00 instead of' the required $715.00. Because refunds can take months to process I am returning the check to you and requesting that you send a new one made out for the corTect amount of $715.00. Please provide the requested information to my attention by Friday, June 11, 2004. If you have any questions about this request don't hesitate to contact me at (919) 733-5083, ext. 578. Enclosure:) cc: Stormwater and General Permits Unit ANZ NCDENR Customer Service 1 800 623-6748 Sincerely, Aisha 1-I. Lau Environmental Engineer Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 ocloF �! a Cfj y iJ Michael F. Easley Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources 0 Alan W. Klimek, P.E. Dirceior Division of Water Quality May 14, 2004 lwls. Tina Lanier, CIVIC City Clerk City of Lexington 22 West Center Street Lexington, NC 27292 Subject: Incomplete Application Davidson County and City of Lexington VIS4 Application Davidson County Dear Ms. Lanier: Your application for Davidson County's and the City of Lexington's combined stormwater permit was received on April 29, 2004. The application is incomplete at this time because it was not. accompanied by the $715 application fee. The check needs to be made payable to NCDENR. ['lease provide the requested information to my attention by Friday, June 4, 2004. If you have any questions about this request don't hesitate to contact me at (919) 733-5083, ext. 578. cc: Stormwater and General Permits Unit ::�*A NCDENR Customer Service 1 800 623.6748 Sincerely, " )/ Aisha I-1. Lan Environmental Engineer Division of Water Quality 1617 Mail Service Center Raleigh, NC. 27699-1617 (919) 733.7015 LUU`! , Phase II Comprehensive Stormwater Management Program Report Davidson County �l City of Lexington Pursuant to NCDENR•DWQ Form SWU-268.103102 Submitted April 2004 Prepared by: HDR Engineering, Inc. of the Carolinas NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC TABLE OF CONTENTS 1.0 STORM SEWER SYSTEM INFORMATION.......................................................1 1.1 Population Served............................................................................................1 1.2 Growth Rate.....................................................................................................1 1.3 Jurisdictional and MS4 Service Area...........................................................1 1.4 MS4 Conveyance System............................................................................1 1.5 Land Use Composition Estimates................................................................1 1.6 Estimate Methodology.................................................................................2 1.7 TMDL Identification....................................................................................2 2.0 RECEIVING STREAMS..........................................................................................3 3.0 EXISTING WATER QUALITY PROGRAMS.....................................................4 3.1 Local Programs................................................................................................4 3.2 State Programs.................................................................................................4 4.0 PERMITTING INFORMATION ............................................. ...5 ............................ 4.1 Responsible Party Contact List........................................................................5 4.2 Organizational Chart ........................................................................................6 4.3 Signing Official......................................................................... .. 6 4.4 Duly Authorized Representative...................................................................... 6 5.0 CO -PERMITTING INFORMATION (NOT APPLICABLE).............................7 6.0 RELIANCE ON OTHER GOVERNMENT ENTITY..........................................8 6.1 Name of Entity................................................................................................. 8 6.2 Measure Implemented...................................................................................... 8 6.3 Contact Information......................................................................................... 8 6.4 Legal Agreements ................... ............................. 8 7.0 STORMWATER MANAGEMENT PLAN............................................................9 7.1 Public Education and Outreach on Storm Water Impacts...............................9 7.2 Public Involvement and Participation............................................................12 7.3 Illicit Discharge Detection and Elimination .................................................. 15 7.4 Construction Site Stormwater Runoff Control..............................................20 7.5 Post -Construction Storm Water Management in New Development and Redevelopment............................................................................................... 20 7.6 Pollution Prevention/Good Housekeeping for Municipal Operations ..........24 Pursuant to NCDENR/DWQ Form i April 2004 SWU-268403102 NPDES Phase II - Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC LIST OF TABLES 2.1 Receiving Streams........................................................................................................3 4.1 Contact Information for Responsible Parties............................................................... 5 7.1 BMP Summary Table of Public Education and Outreach.........................................10 7.2 BMP Summary Table for Public Involvement and Participation .............................13 7.3 BMP Summary Table for Illicit Discharge Detection and Elimination Program .....16 7.4 BMP Summary Table for Post -Construction Stormwater Management in New Development and Redevelopment............................................................................ 22 7.5 BMP Summary Table for Pollution Prevention and Good Housekeeping ................ 25 LIST OF FIGURES 1 Organization Chart for the Stormwater Management Program .................. R Pursuant to NCDENR/DWQ Form S WU-268-103102 April 2004 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 1.0 STORM SEWER SYSTEM INFORMATION 1.1 Population Served The United States Census reports a permanent population of 147,246 in Davidson County (County) and 19,953 in the City of Lexington (City), North Carolina in 2000. The State Office of Planning estimated Davidson County's 2002 population at 150,799 and estimated Lexington's 2002 population at 20,327. The County and the City do not experience significant seasonal changes in population. 1.2 Growth Rate Based upon the decennial censuses of 1990 and 2000, the annualized growth rate for the County is 1.52 percent and the annualized growth rate for the City is 1.87 percent. 1.3 Jurisdictional and MS4 Service Area Davidson County encompasses over 567 square miles, which includes Lexington, Thomasville, Denton, Welcome, and portions of High Point. The current jurisdictional and MS4 service area is the 17.6 square miles of the City of Lexington. The City does not have an extra territorial jurisdiction (ETJ). 1.4 MS4 Conveyance System The County does not own'or operate a MS4 conveyance system. The City has not developed a service area wide inventory and mapping of its MS4 conveyance system. The system consists of constructed curb and gutter with piping. The City performs minimum maintenance on the system, cleaning ditches and culverts as required to avoid hazardous conditions. 1.5 Land Use Composition Estimates The Land Use Composition for the County is estimated to be: • Residential: 43.0% • Commercial: 4.0% • Industrial: 6.0% • Open space: 3.7% • Vacant or other classification: 43.3% Pursuant to NCDENRIDWQ Form 1 April 2004 ' SWU-268-103102 NPDES Phase II -- Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC The Land Use Composition for the City is estimated to be • Residential: 30.4% • Commercial: 5.6% • Industrial: 11.7% • Institutional: 7.9% • Open space: 7.3% • Vacant or other classification: 37.1% 1.6 Estimate Methodology The Land Use Composition for the County was estimated using GIS software and Iand use and zoning data from GIS staff. Totals of each group were calculated in ArcView ® and divided by the total jurisdictional area to obtain percentages. Open space was estimated based upon governmental -maintained parks, greenways, federal game land, and water supplies. Land use information for the City was obtained from the Lexington Land Use Plan 2003. 1.7 TMDL Identification There are no TMDLs developed for streams within the MS4 (City of Lexington) service area. Pursuant to NCDENR/DWQ Form 2 April 2004 S W U-268-103102 NPDES Phase II - Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 2.0 RECEIVING STREAMS The stream segments within the MS4 (City of Lexington) listed by NCDENR in its B1MS database are presented in Table 2.1. The associated classification and use support information are included in the Table. The use support ratings were obtained from the 2003 Yadkin -Pee Dee River Basinwide Water Quality Plan prepared by NCDENR Division of Water Quality. Table 2.1 Stream Basin Index Number Classification Use Support Rating North Potts Creek Yadkin 12-112 C Not Rated Swearing Creek Yadkin 12- l 13 C Impaired Michael Branch Yadkin 12-113-3 C Not Rated Rat Spring Branch Yadkin 12-1 t3-5 C Not Rated Rocky Spring Branch Yadkin 12-113-6-1 C Not Rated Abbotts Creek Arm of High Rock Lake Yadkin 12-118.5 WS-V, B Impaired Abbotts Creek Yadkin 12-119-(6) C Not Rated ro3 - b-4 - 01 Pursuant to NCDENR/DWQ Form 3 April 2004 S W U-268-103102 M NPDES Phase 11— Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC EXISTING WATER QUALITY PROGRAMS 3.1 Local Programs Water Supply_ Watershed Protection Program, Davidson County is a participant in this program and has the necessary controls in place to meet those regulations. The County adopted a Watershed Protection Ordinance in December 1993. A riparian buffer measure is included in the Watershed Protection Ordinance. The measure calls for undisturbed riparian buffers to be maintained on all sides of perennial streams. The stream buffers are to be established on both sides of perennial streams that are shown on the most recent 7.5-minute USGS topographic maps. The width of the buffer measured perpendicular from the average annual stream bank is a minimum distance of 50-feet. 3.2 State Programs Erosion and Sediment Control Program. The North Carolina Division of Land Resources administers the Erosion and Sediment Control Program. At this time the County does not intend to seek a delegated local program. Pursuant to NCDENR/DWQ Form 4 April 2004 S W U-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 4.0 PERMITTING INFORMATION 4.1 Responsible Party Contact List Table 4.1 Control City County Measure Contact Position Phone/Fax/ .:. , , Contact Position Phone/Fax/; - _Email� - Public Education Roger Spach Superintendent 336-248-3970 Guy Director 336-242-2220 and Outreach of Water Resources 336-249-3584 (F) roaers@lexingtonnc.net Comman of Planning 336-242-2222 (F) gcornman@co.davidson.nc.us Public Participation and Involvement Illicit Discharge Rick Austin Director of 336-248-3930 Bill Clutter Director 336-242-2007 Detection and Public Works 336-249-3584 (F) of Public 336-242-1203 (F) Elimination ricks@lexingtonnc.net Works wciutter@co.davidson.nc.us Post - Construction Runoff Controls Pollution Prevention/ Good Housekeeping for Municipal Operations Construction Site See Below. Runoff Control State Program Phone/Fax . Email Measure Construction Site Gray Hauser NCDENR — DLQ Erosion and 919-733-4574 I Gray.Hauser@ncmail.net Runoff I Sediment Control Section Chief 919-733-2876 (F) Pursuant to NCDENRIDWQ Form 5 April 2004 S W U-268-103102 NPDES Phase II - Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 4.2 Organizational Chart County Commissioners I I City Council Robert Hyatt John Gray County Manager City Manage Bill Clutter Guy Cornman Rick Austin Public Works Director Planning Director Public Works Director Figure 1 Post - Construction Civil Engineer Roger Spach Superintendent of Water Resources Illicit Discharge Industrial Pretreatment Supervisor 4.3 Signing Official The County Manager, as principal executive officer, is the signing official for Davidson County. The City Manager, as principal executive officer, is the signing official for the City of Lexington. 4.4 Duly Authorized Representative (Not Applicable) Bruce Davis Director of Recreation Good Housekeeping Public Buildings Supervisor Pursuant to NCDENRIDWQ Form 6 April 2004 SWU-268-103102 NPDES Phase II - Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 5.0 CO -PERMITTING 5.1 Co-Permittees Davidson County City of Lexington Contact: Robert Hyatt Contact: John Gray 913 Greensboro Street 28 West Center Street Lexington, NC 27292 Lexington, NC 27292 Davidson County does not hold any NPDES permits. Current NPDES Permits held by the Citv ofLexinj?ton: Permit Facility NCO055786 Lexington Wastewater Treatment Plant NCO028037 Lexington Water Treatment Plant 5.2 Legal Agreements k7w Presently, there is not a legally binding inter -local agreement. The County and the City intend to work towards an agreement for administering the stormwater program. As an example, the County and the City recently signed an a formal Agreement for wastewater services that establishes wastewater capacity allocations, ownership, operations, and maintenance responsibilities, collection system extension policies, connection and user fees, connection considerations, billing requirements, management, coordination, and other issues. Responsible Parties Control Measure, Responsible Party Public Education and Outreach 50% County, 50% City _..-.--..---._-.--.-.-_.-_-.--._-.-.-_...._.-.-.-------------------- ------------- --- - Public Involvement and ----------............... ........ -........... ...................... 50% County, 50% City Participation Illicit Discharge Detection and 25% County, 75%City Elimination Post -Construction Runoff Control 25% County, 75% City Good Housekeeping 50% County, 50% City Construction Site Runoff State Program Pursuant to NCDENR/DWQ Form 7 April 2004 S W U-268- t 03102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 6.0 RELIANCE ON OTHER GOVERNMENT ENTITY Davidson County and the City of Lexington will rely on the NC Department of Environmental and Natural Resources Sediment and Erosion Control Program for its construction activities. 6.1 Name of Entity North Carolina Department of Environment and Natural Resources - Division of Land Quality 6.2 Measure Implemented Construction Site Runoff Control — Erosion and Sediment Control implementation and enforcement pursuant to the Sedimentation Pollution Control Act, G.S. t 13A-50 et seq. 6.3 Contact Information Gray Hauser, PE State Sedimentation Specialist 1601 Mail Service Center Raleigh, NC 27699 Regional Contact Matt Gantt 585 Waughtown Street Winston-Salem, NC 27107 6.4 Legal Agreements — Not Applicable Pursuant to NCDENR/DWQ Form 8 Apri12004 S W U-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.0 STORMWATER MANAGEMENT PLAN 7.1 Public Education and Outreach on Storm Water Impacts 7.1.1 BMP Summary Table Table 7.1 on page 10 lists the BMP Summary Table for this stormwater program measure. 7.1.2 Target Audience The target audience for the public education and outreach program is a diverse group of citizens who share the range of impact on stormwater. Public education materials and activities will be directed towards industry, commercial business, and developers. The purpose in reaching this sector will be to reaffirm their knowledge in proper waste disposal compliance and facility/site management and operation. This is a group where substantial awareness can lead to major improvements in the environment. The middle target audience includes homeowners, small business operators, and the general public. Education efforts at this level will focus on awareness of stormwater management, proper disposal of common pollutants, and good housekeeping and pollution prevention on one's property. This sector must realize that their contributions may be minimal but that their collective effort produces the maximum result. 7.1.3 Target Pollutant Sources Several pollutant sources have been identified for the concentration of education efforts. These pollutant sources are categorized as household wastes (oil, detergents, paints, and solvents), commercial waste, land application pollutants (fertilizers, pesticides, and herbicides), and organic/land derived pollutants (leaves, grass, sediment, and fecal coliform). These sources have been identified for their frequent use or appearance in the lives of the identified target audience. These sources are also highly controllable with the education of citizens on proper waste disposal procedures, knowledge on the use and function of a storm sewer system, and the recommendation of non -threatening products and procedures like biodegradable products or composting. Pursuant to NCDENWDWQ Form 9 April 2004 SWU-268-103102 NPDES Phase If — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC Table 7.1 BMP Summary Table of Public Education and Outreach No. BMP Measurable Goal Year Year Year Year Year Responsible Party/Person 1 2 3 4 5 1 Publish the number for the Published via local cable access and utility bill City Superintendent of Water environmental hotline inserts. X X X X Resources and the County Planning Director 2 Resident information outreach. Improved content of stormwater information City Superintendent of Water presented at booths at the County Fair and at the 2 2 2 2 2 Resources and the County Planning Barbeque Festival. Units of measure in number Director of events hosted 3 Civic forums and seminars Units of measure in number of events hosted City Superintendent of Water with stormwater content 1 0 1 0 1 Resources and the County Planning resented by staff. Director 4 Cable television (local Units of measures in number of different public City Superintendent of Water government access channel) service announcements shown 1 2 4 6 6 Resources and the County Planning stormwater public service Director announcements 5 Host stormwater program for Units of measure in number of events hosted City Superintendent of Water City and County staff. L I 1 1 1 Resources and the County Planning Director 6 Business and Developer Units of measure in number of events hosted City Superintendent of Water Community Workshop 0 1 0 1 0 Resources and the County Planning Director 7 Environmental Education Units of measure in number of events hosted City Superintendent of Water Outreach for Elementary 0 3 3 3 3 Resources and the County Planning School Students Director 8 Utility bill inserts with lawn Units of measure in inserts distributed City Superintendent of Water care/car wash and other 13MP 22k 22k 22k 22k 22k Resources and the County Planning descriptions Director 9 Stormwater Information added Units of measure in packages distributed City Superintendent of Water to new resident information 0 0 100 200 200 Resources and the County Planning acka es Director X — Denotes items to be completed without other measure. Pursuant to NCDENR/DWQ Form 10 April 2004 S WU-268-103102 NPDES Phase II -- Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 71.4 Outreach Program The community will be informed about stormwater pollution in a variety of ways. The outreach program will use utility bill inserts and new resident information packages to educate homeowners about lawn care/car washing BMPs, proper household waste disposal, and other BMPs that can be started at home. Public service announcements on cable television system will reinforce these suggested BMPs and promote greater awareness of stormwater protection. Strategic airing of the public service announcements may also serve as a invitations for community activities a like the Big Sweep. Educational seminars will be held for local developers, engineers, civic organizations, and businesses to inform them of the new requirements. 7.1.5 Decision Process The decision process for the public education and outreach program focuses on four important objectives: diversity of audience, variety of program BMPs, timing of implementation, and strengthening of existing programs. These methods described in Table 7.1 were chosen because they represent a balance between cost and effective education. 7.1.6 Evaluation The public education and outreach program has attainable and measurable goals. The County and City plan to create an internal committee including the City and County Public Works Directors, the County Planning Director, the City Water Resources Superintendent and other interested parties to annually review and report to the Board of Commissioners and the City Council the status of the program. 1 This committee will meet with the Stormwater Advisory Group to obtain their input on the success of the program prior to completing the annual ' report. The performance measures noted in the BMP Summary Table will be tabulated annually and included in a report to the County Commissioners, City Council, and DWQ. Needed program modifications ' will be reported to the Board and proposed in the annual report to DWQ. Pursuant to NCDENR/DWQ Form 11 AA ri12004 S WU-211-101102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.2 Public Involvement and Participation a7.2.1 BMP Summary Table a Table 7.2 on page 13 lists the BMP Summary Table for this stormwater program measure. 7.2.2 Target Audience The target audiences include the general public and students. The general public will be invited to participate in meetings, organized by staff, in which the goals and objectives of the program are explained and public comment is requested. 7.2.3 Participation Program A Stormwater Advisory Group was created to meet permit requirements for public involvement. The Group was formed in February 2004. The ongoing participation BMPs described in the BMP Summary Table will be used to maintain public awareness and involvement. As the program is implemented, it will be necessary to continue to receive public comments, evaluations, and recommendations from the Stormwater Advisory Group to refine and improve services. This Group will continue to meet beyond the permit application date in the manner befitting the stormwater program and committee participants. Several activities will serve as both educating opportunities and public participation events for the public. Pursuant to NCDENR/DWQ Form 12 April 2004 S W U-268-103102 NPDES Phase II - Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC Table 7.2 BMP Summary Table for Public Involvement and Participation No. BMP Measurable Goal Year Year Year Year Year Responsible 1 2 3 4 5 Party/Person 1 Stormwater Advisory Group Continue Stormwater Advisory Group process. 2 2 2 2 2 City Superintendent of Units of measure in annual meetings Water Resources and the County Planning Director 2 Big Sweep — stream clean up Participate in promoting X X X X X City Superintendent of activity Water Resources and the Count Plannin Director X — Denotes items to be com leted without other measure. Pursuant to NCDENR/DWQ Form 13 April 2004 SWU-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.2.4 Decision Process A successful stormwater program is envisioned as one that provides the benefactors the opportunity to contribute and participate in a program of their design. Crafting the perspective of a program developed by its service constituents will encourage more participation than one handed down and mandated by local government. While there are certain mandatory measures to be achieved in the Phase II permit, there is much latitude in how to reach these goals and it is the public's responsibility to shape their program to their community's needs. The Stormwater Advisory Group will continue to be engaged in dialogue. The Stormwater Advisory Group process has helped and will continue to assist in soliciting ideas on the level of service wanted by the public. This process will assist in refining the draft "Stormwater Quality Management and Discharge Control Ordinance" (Stormwater Ordinance). The importance of embracing representatives from geographically distributed groups within the County is recognized. It is necessary to coordinate on a common regional vision for Stormwater management. Doing so will assist in sharing resources and alleviating inconsistency in service along jurisdictional lines. It is also important to reach out to a variety of stakeholders and disciplines in selecting these committees. Their comments and decisions will filter down to program elements tailored to the citizens they represent. 7.2.5 Evaluation The evaluation of the suggested BMPs for the public participation and involvement element will be judged on the increase of participation of the volunteers in the Big Sweep and the regular continuance of the Stormwater Advisory Group. Increases in volunteers equate to more miles of streams that are cleaned. As mentioned before, the Stormwater Advisory Group will continue to meet on a less frequent but regular basis. Pursuant to NCDENRIDWQ Form 14 April 2004 S W U-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.3 Illicit Discharge Detection and Elimination 7.3.1 BMP Summary Table Table 7.3 on page 16 lists the BMP Summary Table for this stormwater program measure. As the County does not own or operate an MS4, only illicit discharge detection and elimination control measures will be implemented and enforced inside the MS4 of the City of Lexington. However, the intent of the County Stormwater Ordinance is to outlaw illicit discharges throughout the County's jurisdiction. The County also intends to develop an appropriate enforcement program. 7.3.2 Storm Sewer System Map The City will be developing a storm sewer system map covering infrastructure inside its municipal limits over the next 5 years. High priority areas will be identified during the first year of the program and a mapping schedule will be developed. Existing USGS topographic mapping and other appropriate data sources will be used. The storm sewer infrastructure will be surveyed traditionally or with a mobile GPS receiver and the characteristics of the system will be attributed. Structures, such as catch basins, drop inlets, manholes, pipe outfalls, etc will be surveyed for GPS coordinates and attributed for their condition, material, structure depth, pipe depth, etc. Pipes will be attributed for many of the same characteristics but also include descriptions on their entrance and exit features as well as their diameter and geometry. This inventory will include systems existing or beginning in the public right-of-way and systems that have outfalls on receiving streams. 7.3.3 Regulatory Mechanism With the Stormwater Advisory Committee, the County and the City are developing a Stormwater Ordinance. Illicit discharge prohibition will be addressed in the Stormwater Ordinance. Non-stormwater illicit discharges will be prohibited from being released into the receiving waters of the County or other delegated jurisdiction. The ordinance will also allow for inspection and elimination of these discharges. The goal is to meet the minimum requirements by adopting the Stormwater Ordinance by August 2005. Pursuant to NCDENR/DWQ Form 15 April 2004 aSWU-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC Table 7.3 BMP Summary Table for Illicit Discharge Detection and Elimination Program Year Year Year Year Year Responsible No. BMP Measurable Goal 1 2 3 4 5 Party/Person I Develop the procedures for mapping Agreement by Stormwater Advisory Group on X County and City Public the highest priority areas procedure and ranking of highest priority areas and Works Directors survey schedule 2 Develop the field investigation Identify all equipment and material required. X County and City Public methods for illicit discharge detection Works Directors 3 Train stormwater staff on procedures Units of measure in staff trained 1 1 2 2 County and City Public for investigating illegal discharges and Works Directors e ument use i 4 Include provisions in the Stormwater Adopt and begin enforcing the measures of the X X X X X County and City Public Ordinance for the prohibition of illicit Stormwater Ordinance Works Directors connections and illegal discharges 5 Establish the City's environmental Operate an environmental concerns hotline for X X X X X County and City Public concern hotline response to reports occurrences inside City limits. Works Directors inside City limits. 6 Train fire inspectors in how to discover Units of measure in fire inspectors trained 2 2 and report illicit discharges or County and City Public connections they encounter during Works Directors annual inspections 7 Conduct pilot storm sewer inventory Survey at least 5 miles of stream and stormwater X in City MS4 (and illicit discharge infrastructure. County and City Public survey) in selected basins to evaluate Works Directors and refine procedures 8 Develop storm sewer map showing the Electronic maps of all outfalls within the City MS4 X X X X City MS4 outfalls and receiving waters will be prepared and maintained. Locations will be County and City Public of the US. surveyed either by traditional methods or by using Works Directors GPS. Sections of the MS4 will be completed over ears 2 through 5. 9 Perform illicit discharge surveys and In year 3 begin using mapping data collected X X X dry weathering screening, previously to conduct outfatl dry weather screening. County and City Public Follow suspected sources through the system and Works Directors pursue 100% of illicit discharges for corrective action. X — Denotes items to be completed without other measure Pursuant to NCDENR/DWQ Form 16 April 2004 S WU-268-103102 NPD€S Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.3.4 Enforcement The enforcement plan will include a two -stage process. The first phase is a public education period for the citizens about the illicit discharge program, its inherent regulations in the Stormwater Ordinance, and the impacts of its disregard and violation. At the target date of August 2006, a full year after the target date for adoption of the Stormwater Ordinance, the staff will begin full enforcement of its ordinance, serving notices, warnings, and civil penalties as outlined in the Stormwater Ordinance. This process is appropriate in providing ample time for citizen awareness of a program that can carry serious implications. 7.3.5 Detection and Elimination Staff will attempt to locate facilities, homes, or properties that are unlawfully discharging into the City's MS4. The Stormwater Ordinance grants the staff the right to enter a private property and to further investigate, monitor, test, or sample discharges from the property, in order to confirm a violation. In the event that illegal discharge is detected, the owner will be notified of the detected illegal discharge with remedial action to be taken and a time frame in which the action is to be completed. In the first permit year of the Illicit Discharge Detection and Elimination Program, staff will concentrate on locating the highest priority areas and developing field survey methods to locate sources. Some analysis will involve overlaying datasets like NPDES wastewater discharges, industrial land use density, and older development density to amass probable areas. Other analysis will highlight areas of repetitive citizen's complaints, water quality violations, and stream impairment. A hotline will field illegal discharge/dumping and spill reports, which will be of assistance in classifying high priority areas. With high priority areas identified, stormwater staff will perform a preliminary stage of illicit discharge surveying. Several methods and tools will be used in determining a source of an illegal discharge. The storm sewer inventory will serve as the most valuable tool for locating illegal discharges. The blueprint of drainage for the City will enable staff to back track discharges along storm sewer lines and through structures to the probable property of the illegal discharge. Illicit discharge detection will occur through both the storm sewer inventory process and dry weather screening (greater than 72 hours without rainfall). Pursuant to NCDENR/DWQ Form 17 April 2004 SW U-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.3.5.1 Procedures for Locating Priority Areas Aging infrastructure will be identified. In addition, on -site inspections will be conducted in conjunction with the annual Fire Department inspection program. 7.3.5.2 Procedures for Tracing the Source County and City employees will be trained on illegal dumping, illicit discharge and ways to identify illicit connections. Upon discovery of dry weather flow, the survey will document the location and attempt to follow the flow upstream to its source. Several methods will be utilized to identify illicit connections. Tracing suspect discharges is likely to begin in Year 3 of the program. 7.3.5.3 Procedures for Removing the Source Discovered sources will be documented. The property owners will be notified of the required remedial measures and a timeframe in which to complete them. If fecal coliform discharge is discovered, the County Health Department will be notified. a7.3.5.4 Procedures for Evaluation of the Plan The number of illegal discharges detected and eliminated will be tracked to evaluate the program. 7.3.6 Non-Stormwater Discharges The Stormwater Ordinance lists several non-stormwater discharges that when properly managed to ensure that no potential pollutants are present, can be discharged the receiving waters. They include: • Potable water line flushing, • Uncontaminated pumped groundwater and other discharges from potable water sources, • Landscape irrigation and lawn watering, • Diverted stream flows, • Rising groundwater and groundwater infiltration to the storm drain system, • Uncontaminated foundation and footing drains, • Uncontaminated water from crawl space pumps, • Air conditioning condensation, • Springs, • Occasional individual residential car washing, Pursuant to NCDENR/DWQ Form B April 2004 S W U-261-103 102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC • Flows from riparian habitats and wetlands, • Dechlorinated swimming pool discharges, • Street wash waters, and • Flows from fire fighting. O7.3.7 Other Incidental Stormwater Discharges Other incidental non-stormwater discharge: Occasional, non-commercial car washing (for charity events, churches, etc.) will be allowed. Limitations will be placed on the frequency of events and the location of the events (prohibited inside the critical area of water supply watersheds). 7.3.8 Outreach The Public Education component of the program will be used to inform citizens of the hazards and illegality of illicit discharges and connections. County and City employees will be trained in the identification of possible illicit discharges. They will use that training to better educate the community about the impacts of such discharges and about requirements and procedures. 7.3.9 Decision Process The capabilities and the limitations of the current and anticipated staff were factored into the decision process. An enforcement process is incorporated into the Ordinance and a realistic and effective set of BMPs has been selected. After the first year's training, prioritization and mapping program are completed the detection and elimination portions of the program will proceed. 7.3.10 Evaluation The County and City plan to create an internal committee including the City and County Public Works Directors, the County Planning Director, the City Water Resources Superintendent and other interested parties to annually review all measurable goals to determine if they are being effectively met and if the BMPs are still the best choice to attain the overall objective. This committee will also meet with the Stormwater Advisory Group to obtain their input on the success of the program prior to completing the annual report. Needed program modifications will be reported to the Commissioners, Council, and proposed in the annual report to DWQ. Pursuant to NCDENRIDWQ Form 19 April 2004 SWU-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.4 Construction Site Stormwater Runoff Control The County and City will rely on the North Carolina Department of Environment and Natural Resources — Division of Land Quality to ensure compliance with this a NPDES Phase If measure at this time. The County has plans to include language in the Stormwater Ordinance that provides for conditional approval of stormwater permits if a sediment and erosion control permit is required. 7.5 Post -Construction Storm Water Management in New Development and Redevelopment 7.5.1 BMP Summary Table Table 7.4 on page 22 lists the BMP Summary Table for this stormwater program measure. aAs the County does not own or operate an MS4, only post -construction runoff control measures will be implemented and enforced inside the MS4 of the City of Lexington. 7.5.2 Non -Structural BMPs Davidson County currently regulates land development and protection with its Subdivision, Zoning, Flood Damage Prevention, and Watershed Protection Ordinances. The Subdivision and Zoning ordinance are administered by the Planning Department. The Flood Damage Prevention and Watershed ordinances are also administered by the Planning Department. In its first implementation year, the Davidson County staff will review the Zoning and Subdivision ordinances for regulations detrimental to effective stormwater management. The staff will make recommendations to the County Manager for modifications of the current regulations where necessary. The City of Lexington currently regulates land development within its municipal limits through the Zoning Ordinance and the Subdivision Ordinance administered by the Planning Department. In its first year of implementation, the Lexington City staff will review these ordinances for regulations detrimental to effective stormwater management. The staff will make recommendations to the City Manager for modifications of the current regulations where necessary. As part of the post construction controls, the stormwater staff will administer a site plan review process. Developments legally required by the new Stormwater Ordinance to submit a plan will be reviewed for Pursuant to NCDENR/DWQ Form 20 April 2004 S W U-218-103102 NPDES Phase 11— Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC compliance and performance. This opportunity will allow for the stormwater staff to identify potential problems to developers. Notable areas of suggestion include the minimization of the disturbance to soils and vegetation, impervious areas, and directly connected impervious areas. 7.5.3 Structural BMPs Through discussions with the Stormwater Advisory Group, the City will develop a menu of approved structural BMPs for developers and owners to use for the control and treatment of stormwater on their properties. This menu will include a variety of BMPs satisfying storage, filtration, and infiltration practices or combinations thereof. The BMP menu will be located in the Technical Standards Manual and will include design and performance specifications. 7.5.4 Regulatory Mechanism A target date for adoption of the Stormwater Ordinance has been set for August 2005. The ordinance is in draft form and will be refined based upon recommendations from the Stormwater Advisory Group. 7.5.5 Operation and Maintenance The Ordinance will require operators and owners of stormwater facilities to perform regular maintenance. Owners are required to enter into a written inspection and maintenance agreements that are enforceable upon the owner's successors and assignees. If necessary maintenance is not performed in a satisfactory manner or time, the County and/or City reserve the right to enter the property after sufficient notice and complete or correct the maintenance work. Another part of the agreement provides that the stormwater facilities and additional area for access be recorded as an easement. This easement and the written inspection and maintenance agreement are recorded with the Register of Deeds. Pursuant to NCDENRIDWQ Form 21 April 2004 S W U-268-103102 NPDES Phase II - Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC Table 7.4 BMP Summary Table for Post -Construction Stormwater Management in New Development and Redevelopment Year Year Year Year Year Responsible No. BMP Measurable Goal 1 2 3 4 S Party/Person 1 Develop ordinance to control peak Approve ordinance and inform public of its details X County and City Public runoff volumes and remove TSS. and impact Works Directors 2 Include language in ordinance to Approve ordinance and inform public of its details X County and City Public protect riparian areas along perennial and impact Works Directors and intermittent streams 3 Implement and administer a site plan Initiate program one year after the adoption of the X X X X County and City Public review process Stormwater Ordinance Works Directors 4 Review and document construction Initiate program one year after the adoption of the X X X X County and City Public phase and as built inspections Stormwater Ordinance Works Directors 5 Develop and administer an in-house Initiate program one year after the adoption of the X X X X County and City Public structural BMP inspection program Stormwater Ordinance Works Directors X — denotes items to be completed without other measure Pursuant to NCDENR/DWQ Form 22 April 2004 S WU-238-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.5.6 Decision Process Much of the decision -making on this program element was based on the blending of existing regulations and procedures in place in the County and/or City with the fulfillment of the NPDES Phase Il requirements. 7.5.7 Evaluation The County and City plan to create an internal committee including the City and County Public Works Directors, the County Planning Director, the City Water Resources Superintendent and other interested parties to annually review all measurable goals to determine if they are being met effectively. Measurable goals for the post -construction runoff control program will be the implementation of each BMP for its scheduled time. Several of the 1 latter elements like site plan review, construction phase and as built inspection and structural BMP inspection are highly dependent on the adoption of the Stormwater Ordinance. If the Stormwater Ordinance is ' not adopted on schedule than these elements will likely be delayed as well. ' The committee will also meet with the Stormwater Advisory Group to obtain their input on the success of the program prior to completing the annual report. Needed program modifications will be reported to the ' Commissioners, Council, and proposed in the annual report to DWQ. 1 Pursuant to NCDENR/DWQ Form 23 April 2004 S W U-261-103102 aNPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.6 Pollution Prevention/Good Housekeeping for Local Government Operations 7.6.1 BMP Summary Table Table 7.5 on page 25 lists the BMP Summary Table for this stormwater program measure. 7.6.2 Affected Operations Potentially impacted municipal operations by this program include the operations of the Utility, Engineering, Planning, and other departments of Davidson County and the City of Lexington. There are several facilities that do not require municipally owned permitting, but that will be addressed by the County's Pollution Prevention and Good Housekeeping program. These facilities include: • Fleet Management (County and City) • Lexington Municipal Golf Course ' • Parks and Recreation Department (County and City) 7.6.3 Training The staff will perform in-house training of the County and City employees on pollution prevention and better operations management. This training will be provided on an annual basis and targeted to a certain number of events per year. Existing material from other public education programs ' may be used but this training will also require site and operation specific materials. 7.6.4 Maintenance and Inspections The staff will review the County and City procedures and methods for pollution prevention ideas, specifically the proper use of fertilizers and pesticides on government -owned properties. The proper application of fertilizers may contribute to a reduction in pollution to area streams. ' Reduced mowing around waterways on County and City properties will encourage growth of the riparian habitat where it may have been destroyed. 1 Pursuant to NCDENR/DWQ Form 24 April 2004 S W U-268-103102 NPDES Phase II - Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC Table 7.5 BI\4P Summary Table for Pollution Prevention and Good Housekeeping for Local Government Operations No. BMP Measurable Goal Year Year Year Year Year Responsible 1 2 3 4 5 Party/Person Review of local government operations Develop pollution prevention plan and use as model X X X X County and City Public and facilities for implementation of for other City and County owned facilities Works Directors pollution prevention 2 Train employees in pollution Annually train some percentage of employees 10 15 20 25 30 County and City Public prevention and proper disposal of Works Directors wastes 3 Review fertilizer and pesticide use by Review Completed X X County and City Public local government employees Works Directors 4 Review and monitor local government Document schedules and scopes of work to be X X X X County and City Public operations in or near riparian buffers performed around riparian buffers and encourage Works Directors timelycompletion X — denotes items to be completed without other measure Pursuant to NCDENRIDWQ Form 25 April 2004 SWU-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.6.5 Vehicular Operations An audit of fleet management sites will lead to the development of a pollution prevention plan. Some areas of review will include the practices of the fleet repair and maintenance staff, including the storage of the vehicles in the parking lot itself. The pollution plan will recommend practices to ensure the proper disposal of vehicle parts and used materials and a BMP for filtering out vehicle residues from parking lot runoff. As part of the pollution prevention plan, the staff will review current vehicle washing procedures for potential improvements in pollution control. It may be necessary to construct and implement protocol for a vehicle pre -wash facility that will collect used wash water for pretreatment or disposal into the City's sanitary sewer. 7.6.6 Waste Disposal Davidson County operates several waste disposal facilities such as a landfill, a household hazardous waste facility, and recycling convenience centers. To ensure the proper disposal of certain wastes, the County will train County employees in the location of these facilities and their waste acceptance practices. 7.6.7 Flood Management Projects The County regulates floodplain management through provisions outlined in the Flood Damage Prevention Ordinance. The regulations require the protection of established uses vulnerable to flood damage. The regulations also control any alterations to the floodplains, including stream channels and natural protective barriers. Most floodplain management projects will be subject to stormwater permitting if they disturb the minimum volume of land or occur in the riparian buffer. At that time the stormwater staff will work with the appropriate floodplain management staff to ensure proper water quality protection and compliance. 7.6.8 Existing Ordinances The staff will address activities and services performed within or in the vicinity of riparian buffer systems. These activities will be reviewed for possible problems that may arise by working in these sensitive areas. Additional pollution control measures, such as shorter work schedules may be recommended to ensure the protection of area streams. Pursuant to NCDENRIDWQ Form 26 April 2004 S WU-268-103102 NPDES Phase II — Comprehensive Stormwater Management Program Report Davidson County and the City of Lexington, NC 7.6.9 Other Evaluations There are no other aspects being evaluated at this time. 7.6.10 Decision Process The first step of the municipal pollution prevention plan is to identify all County or City owned properties and areas where services are performed frequently. An internal review of these facilities will take place with emphasis on the evaluation of storage practices of potential pollutants and disposal procedures. The plan will also identify operational procedures that may be improved to decrease pollution contributions. Another facet of the Pollution Prevention and Good Housekeeping program will be the regular training of County and City staff on issues concerning pollution prevention and operations management. The staff will perform the training for this BMP and will target a certain number of employees annually as a goal. Documenting the attendees will serve to identify new individuals each year. 7.6.11 Evaluation The County and City plan to create an internal committee including the City and County Public Works Directors, the County Planning Director, the City Water Resources Superintendent and other interested parties to annually review all measurable goals to determine if they are being met effectively. Objective goals for this evaluation will include obtaining high levels of participation in employee training and general employee environmental awareness. The performance measures noted in the BMP Summary Table will be tabulated annually and included in a report to the County Commissioners, the City Council and to DWQ. Needed program modifications will also be reported and proposed in the annual report to DWQ. Pursuant to NCDENR/DWQ Form 27 April 2004 S W U-268-103102