HomeMy WebLinkAboutNCS000584_APPLICATION_20150602STORMWATER DIVISION CODING SHEET
M54 PERMITS
PERMIT NO.
^ `o
DOC,TYPE
❑FINAL PERMIT
❑ ANNUAL REPORT
C�'A/PPLICATION
❑ COMPLIANCE
❑ OTHER
0 'o � 5 0�C' oZ
DOC DATE
❑
YYYYMMDD
F-Amr-�
LEXINGTON
NORTH CAROLINA
PUI3I.IC SI---I1VIC1:S
S 1, R 1' I C E i 11 1 It S T
May 29, 2015 �.Q �7,j
�t f
Mike Randall 1UN
Stormwater Permitting Program oENR
Mineral and Land Resources DEMLR wArEeR
NC Division of Energy, ( ) 4 FFEF?pESQURCES
1617 Mail Service Center RMrt-rrNG
Raleigh, NC 27699-1617
Dear Mr. Randall,
Enclosed you will find the NDPES Stormwater Permit Application Form with three copies of the
Stormwater Program Management Report. Also enclosed is an envelope with a check for
$860.00 for the application fee.
My contact information is listed in the footer. My cell number is 336.240.1952.
Thank you for your help as Lexington develops a Phase II Stormwater program.
Sincerely,
Roger Jones, PE
City of Lexington
Public Services Manager
Water Resources • Public Works • Engineering
Engineering - Fleet Management - Public Buildings - Recycling & Waste Collection - Street Maintenance - Water Resources
711 S. lalbert Boulevard Mail: 28 West Center Street - I exinPton, NC 27292 - 336.249.3930
)NNIC O W
ItI",( YC1,F FI RS'I'
State of North Carolina OFFIC USE ONLY
Department of Environment & Natural Resources Date Rec'd
Division of water Quality Fee Paid
Permit Number
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 M54 Stormwater
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 Permit Coverage
City of Lexington
b.
Ownership Status (federal,
state or local
Local
c.
Type of Public Entity (city,
town, county, prison, school,
etc.
City
d.
Federal Standard Industrial
Classification Code
SIC 91 - 97
e.
County(s)
Davidson
f.
Jurisdictional Area (square
miles
18
g.
Population
Permanent
18,931 source: 2010 US Census
Seasonal (if available)
h.
Ten-year Growth Rate
-0.60% source: 2000-2010 US Census
L
Located on Indian Lands?
❑ Yes ® No
II. RPE / MS4 SYSTEM INFORMATION
a.
Storm Sewer Service Area
(square miles
9.5 square mile area of storm sewers
b.
River Basin(s)
Yadkin Pee -Dee
c.
Number of Primary Receiving
Streams
Two -
Abbotts Creek & Swearing Creek
d.
Estimated percertage of jurisdictional
area containing the following four land use activities:
•
Residential
56%
%s based on Zoning Classification (no open space
•
Commercial
21%
classified). Lexington is currently developing a data
•
Industrial
23%
base of actual land use available later this year).
•
Open Space
Industrial % may substantially decrease and Open
..................5 ace will be better quantified.
Total =
100%
e.
Are there significant water
quality issues listed in the
attached application report?
❑ Yes
®No
Page 1 3 5- go
5WU 254-103102 O � -5- 3 -! 1p /
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
IV. 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 enti ?
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
❑Yes ®No
with another Phase II entity?
d. If so, provide the name(s) of
the entity:
e. Have legal agreements been
finalized between the co-
❑ Yes ❑ No
—permittees?
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 rmit obligations?
❑ Yes ® No
b. If yes, identify each entity and the element they will be implementing
• Name of Entity
• Element they will implement
• Contact Person
• Contact Address
• Contact Telephone Number
c. Are legal agreements in place
to establish res onsibilities?
❑Yes El 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
N/A
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
5WU-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 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 gatherring 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 for submitting false information,
including the possibility of fines and imprisonment for knowing violations
Signature
Name
J Ian Carson
Title
City Manager
Street Address
28 W Center Street
PO Box
City
Lexington
State
NC
Zip
27360
Telephone
336.248.3910
Fax
E-Mail
IACarson@LexingtonNC.gov
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
Roger Jones
b.
Title
Public Services Manager Water Resources - Public Works - Engineering
c.
Street Address
28 W Center Street
d.
PO Box
e.
City
Lexington
f.
State
NC
g.
Zip
27360
h.
Telephone Number
336.248.3930
i.
Fax Number
336.249,3584
j.
E-Mail Address
RDJones@Lexington NC.Gov
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
NCO055786 & WWO023213
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
N/A
section 404 of CWA
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
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
FAImf-v-�
LEXINGTON
NORTH CAROL] N A
PUBLIC SERVICES
SI-RVIcE FIRST
City of Lexington
Stormwater Management Program
Report
National Pollutant Discharge Elimination
System (NPDES) Phase II
Engineering - Fleet Management Public Buildings - Recycling & Waste Collection - Street Maintenance - Water Resources
711 &'IaIb;erI Boulevard Mail: 28 West Cvvtei Street Iexington, N(' 27292. - 336.248.3930
IC11't'1C'.LI�,XIN(�"l(li`I\C.C(?\'
TABLE OF CONTENTS
1. STORM SEWER SYSTEM INFORMATION
1.1. Population Served...................................................................................................................1
1.2. Growth Rate............................................................................................................................1
1.3. Jurisdictional and MS4 Service Areas.....................................................................................1
1.4. MS4 Conveyance System........................................................................................................2
1.5. Land Use Composition Estimates............................................................................................2
1.6. TMDL Identification.................................................................................................................3
2. RECEIVING STREAMS.....................................................................................................................5
3. EXISTING WATER QUALITY PROGRAMS
3.1. Local Programs.......................................................................................................................7
3.2. State programs.......................................................................................................................7
4. PERMITTING INFORMATION
4.1. Responsible Party Contact List................................................................................................8
4.2. Organizational Chart ...............................................................................................................9
4.3. Signing Official.......................................................................................................................10
4.4. Duly Authorized Representative.............................................................................................10
5. CO -PERMITTING INFORMATION (if applicable)............................................................................11
6. RELIANCE ON OTHER GOVERNMENT ENTITY
6.1. Name of Entity............................................................................. .......12
....................................
6.2. Measure Implemented............................................................................................................12
7. STORMWATER MANAGEMENT PROGRAM
7.1. Public Education and Outreach on Storm Water Impacts.....................................................13
7.2. Public Involvement and Participation.....................................................................................16
7.3. Illicit Discharge Detection and Elimination.............................................................................18
7.4. Construction Site Stormwater Runoff Control.........................................................................23
7.5. Post -Construction Storm Water Management in New Development and Redevelopment....23
7.6. Pollution Prevention/Good Housekeeping for Municipal Operations......................................24
Stormwater Management Plan-
NDPES Phase II
1. Storm Sewer System Information
1.1 Population Served
The City of Lexington was first settled in 1775 and named their community in
honor of Lexington, Massachusetts, the site of the first skirmish of the American
Revolutionary War. Lexington was incorporated in 1828 by the North Carolina
General Assembly and became the county seat of Davidson County in 1847.
Lexington has a long heritage in furniture making and "Lexington style" barbecue.
According to the 2010 US Census, Lexington has a population of 18,931.
Lexington is home to several festivals and events. The two largest are a one day
Barbeque Festival and a multi -day Kansas City sanctioned Barbeque Cook -Off
event. Even though these events represent increases in people within the City
these are considered major events, as opposed to seasonal population that do
not pose additional burden on the City's MS4.
1.2 Growth Rate
Based upon the 2000 and 2010 US Census', the City of Lexington has
experienced a 6.02% decrease in population. This equates to a negative annual
growth rate of-0.60%. The growth rate has been negatively impacted by the
furniture plant closings in the early 2000s which resulted in the loss of
approximately 3000 jobs. Prior to this time period Lexington had a positive
annual growth.
1.3 Jurisdictional and MS4 Service Area
The total jurisdictional area of the City of Lexington is approximately 18 square
miles. From the City's GIS drainage layer the current MS4 service area covers
approximately 9.5 square miles. The remaining area uses ditches and natural
means of conveyance.
Stormwater Management Plan — Page 1 of 26
NPDES Phase 11
1.4 MS4 Conveyance System
The City of Lexington owns and maintains storm sewer systems that are part of
the City maintained street system, City parks, and public building properties. The
systems are comprised of piped drainage and open or natural channels.
The City Street Department performs typical urban maintenance activities which
include replacement of pipes as needed, rebuilding and adding drainage
structures as needed, keeping pipes open and flowing, and cleaning debris from
the tops of catch basins. The Street Department has a sweeper truck that runs
regularly scheduled routes cleaning curb lines of small accumulations of debris
and litter. Emergency responders handle wreckage debris and control fluid
losses at vehicle accident sites. The Street Department supports Emergency
Responders with personnel and a sweeper as needed for clean-up.
Along with weekly waste and recycle collection, the City's Waste & Recycling
Department also weekly operates a knuckle boom truck and crew citywide to
pick-up yard waste and bulk debris. During leaf season, Waste & Recycling is
assisted as needed by the Street Department and Public Grounds to pick-up
leaves; the majority of which are composted at our Sewage Treatment Plant.
The NC Department of Transportation maintains drainage systems within its
publically maintained rights -of -way inside the City. The NCDOT County
Maintenance Unit is based inside the City Limits of Lexington.
Drainage systems in private streets and drainage ways that are outside the
publically maintained areas listed above are maintained by the abutting property
owners.
1.5 Land Use Composition Estimates
The estimated percentage of the City of Lexington's jurisdictional area is as
follows:
Residential 56%
Commercial 21 %
Industrial 23%
Open Space
Stormwater Management Plan — Page 2 of 25
NPDES Phase 11
Land use estimates were taken from the GIS mapping of the City's zoning
classifications. * Lexington does not have an open space zoning classification.
Currently, Lexington is developing a database of each parcel's actual use which
will give a more accurate reflection of land use composition than zoning (which is
potential use). This data base is expected to be completed summer 2015. It is
expected that open space data will be generated and the percent of actual
Industrial land use will decrease.
1.6 TMDL Identification
Lexington is in the Yadkin- Pee Dee River Basin.
Swearing Creek and Abbotts Creek pass within or on the edge of Lexington's
jurisdiction and are listed on the "2014 Category 5 Water Quality Assessments-
303(d) List". However, no TMDLs for these streams have been established at
this time.
Stormwater Management Plan — Page 3 of 26
NPDES Phase 11
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�& Lexington Storm Sewer Pipe System (orange) and Jurisdictional Area
4,500 0 4,600 9,000 0412812015
1 Inch = 4,600 feet P� Feet Public Works Dept.
2. Receiving Streams
The table below lists the primary streams and tributaries for the Yadkin Pee -Dee
River Basin within the City of Lexington. For each stream, that information is
available, the stream segment, water quality classification, use support rating,
and any water quality issues are listed.
RECEIVING
STREAM
WATER
USE WATER
STREAM NAME
SEGMENT
QUALITY
SUPPORT QUALITY
CLASSIFICATION
RATING ISSUES
Swearing Creek
From Old Salisbury Rd
C
to City Limit south
of 1-85
Rat Spring Branch
From Source to
Swearing Creek
From City Limit south
Unnamed
of
Tributary
1-85 to Swearing Creek
North Potts Creek
From City Limit to
City Limit behind
389 Clyde Fitzgerald Rd
SR 1287
Abbotts Creek
From East US HWY 64
to East Center St
SR 1243
Abbotts Creek
From East Center St
C
D
SR 1243 to 1-85
-1
1
Stormwater Management Plan — Page 5 of 26
NPDES Phase 11
RECEIVING
STREAM NAME
STREAM
SEGMENT
WATER
QUALITY
CLASSIFICATION
USE
SUPPORT
RATING
WATER
QUALITY
ISSUES
Unnamed
From source to
Tributary
Abbotts Creek
behind 829 Gray Mill Rd
SR 2465
IL
Unnamed
From source to
Tributary
Abbotts Creek
behind 829 Gray Mill Rd
SR 2465
Stormwater Management Plan — Page 6 of 26
NPDES Phase 11
3. Storm Sewer System Information
3.1 Local Programs
The City of Lexington is not in a protected water supply watershed, but does
have a Land Use Ordinance.
3.2 State Programs
NCDENR located in Winston-Salem manages Erosion and Control.
Stormwater Management Plan — Page 7 of 25
NPDES Phase it
4. Permitting Information
4.1 Responsible Party Contact List
For Measurable Goals except Erosion Control:
Roger Jones, PE
Public Services Manager
City of Lexington
28 W Center St
Lexington, NC 27292
Telephone: (336) 248.3930
Fax: (336) 249.3584
Email: RDJones Lexington N C. gov
For Construction Site Stormwater Run-off Control:
NCDENR Winston-Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
(Main) 336-776-9800
(Fax) 336-776-9797
Stormwater Management Plan — Page 8 of 26
NPDES Phase 11
4.2 Organizational Chart
Lexington
City Council
City Manager
Alan Carson
Assistant City Manager
Terra Greene
Public Services Manager
Water Resources • Public Works -
Engineering
Roger Jones, PE
Stormwater Management Plan — Page 9 of 26
NPDES Phase 11
4.3 Signing Official
The signing official for the application shall be the City Manager. The City
Manager holds the top administrative position responsible for all functions within
the City of Lexington.
4.4 Duly Authorized Representative
The City of Lexington will not delegate responsibility to anyone other than the
signing official.
Stormwater Management Plan — Page 10 of 25
NPDES Phase 11
5. Co -Permitting Information
At this time, co -permitting is not applicable to the City of Lexington's permit
application.
Stormwater Management Plan -- Page 11 of 26
NPDES Phase 11
6. Reliance on Other Government Entity To Satisfy One or
More Permit Applications
For Construction Site Stormwater Run-off Control:
NCDENR Winston-Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
(Main) 336-776-9800
(Fax) 336-776-9797
Stormwater Management Plan — Page 12 of 26
NPDES Phase 11
7. Stormwater Management Program Plan
It is the intent of the City of Lexington to develop, implement, and enforce a
sustainable Stormwater Management Program, suited for our area that will
reduce the discharge of pollutants, protect water quality, and satisfy the
appropriate water quality requirements of the Clean Water Act.
7.1 Public Education and Outreach on Storm Water Impacts
The City of Lexington has for several years contracted with an outside agency to
provide a public education program to distribute educational materials to the
community. In conjunction with our partner the City will continue updating and/or
developing our informational materials.
Also, Lexington issues an annual water quality report that has a segment about
protecting the water supply.
The City of Lexington has several festivals and events throughout the year. The
City will continue building on this opportunity to reach out to the community and
region. In prior years we have had an agency that had a booth to provide
stormwater materials at the annual Barbeque Festival. This one day festival
attracts over 100,000 people to the Uptown Lexington. This agency has also
provided hand-outs at local schools. During this permit period the City will
evaluate how best to build on and expand these outreach programs. We believe
schools, festivals, and events represent the best opportunities and are
Lexington's strength to develop a culture of stormwater awareness.
The City of Lexington has a website, enews, and a cable government channel.
Lexington will use these platforms to raise stormwater awareness, provide
stormwater education, advertise, and promote stormwater outreach activities.
7.1.1 BMP Summary Table
The following table outlines what best management practices the City of
Lexington will use in its education program and the measurable goal.
Stormwater Management Plan -- Page 13 of 26
NPDES Phase 11
BMP's and Measurable Goals for Public Education and Outreach on Stormwater Impacts
BMP
Measurable Goals
1 Distribution of Educational Material
Annual mailings of Water Quality Reports
2 Educational Materials and/or Presentations for Schools
Distribute educational materials to teachers and students
and/or develop age appropriate presentations for students
3 Informational Website
Place information, links, etc. to sites, videos, and articles on
www.lexingttonnc.net
4 Enews
send enews concerning water quality and/or recycling issues
5 Television (Cable Public Access Channel 13)
Advertise stormwater related events and provide educational items
b Recycling Program
Continue current levels of service and programs regarding
household waste collection, scrap tire removal
and white goods collection
Continue adding rollout recycle containers to routes and educate.
the public on its benefits. Currently, the City has completed the
2nd year of a 4 year implementation plan
7.1.2 Target Audience
The City of Lexington recognizes that all facets of its population should be a
target audience for education of stormwater impacts. Lexington will target youth
in schools, water and sewer customers, and engage the general public through
various media and festival events.
7.1.3 Target Pollutant Sources
With the loss of manufacturing, Lexington will target residential causes of
stormwater pollution. This strategy is subject to change as the City re -develops.
7.1.4 Outreach Program
Lexington's strategy for educational outreach is to attempt to touch as many as
possible over this permit period. Methods will need to be tried, evaluated,
refined, and/or refocused over the permit period. The City will promote education
and outreach at festival events to reach the general public, continue to promote
recycling through the rollout recycling program that is being phased in throughout
the City, continue to educate the public on household hazardous waste
collection, solid waste collection, scrap tire removal, and disposal of white goods.
The City will also use Channel 13, enews, and our website to provide education,
links, and links to videos.
7.1.5 Evaluation of Effectiveness
The educational program measure will be evaluated on the number of brochures
distributed, number of events/meetings held and the attendance, amount of air-
time minutes, and the amount of information presented on the website. Once
these items are quantified, metrics going forward can be established.
Stormwater Management Plan — Page 15 of 26
NPDES Phase 11
7.2 Public Involvement and Participation
The City of Lexington will encourage volunteer involvement & participation to
continue building a sustainable program.
7.2.1 BAAP Summary Table
The following table outlines what best management practices the City of
Lexington will use in its Public Involvement/Participation program and the
measurable goal.
Stormwater Management Plan — Page 16 of 26
NPDES Phase 11
BMP's and Measurable Goals for Public Involvement and Participation
BMP
'.'Measurable Goals-
1 Public Hearing
Conduct public meeting to allow citizen input concerning
Stormwater Management Plan
2 Cleaner City Campaign
Appearance Commission will continue the annual springtime
Cleaner City Campaign
3 Recycling Program
Continue current levels of service and programs regarding
household waste collection, scrap tire removal, white goods collection
and leaf/grass, bulk yard/debris collection
Continue adding rollout recycle containers to routes and educate
the public on its benefits. Currently, the City has completed the
2nd year of a 4 year implementation plan
4 Stormwater Contest at a Festival Event
The City will sponsor a stormwater contest at a festival event to
promote public participation to be good environmental stewards
7.2.2 Target Audience
As with education, the City of Lexington desires to reach all its citizens.
7.2.3 Participation Program
The City of Lexington will conduct a public meeting to explain and receive citizen
input of the stormwater plan. The City will encourage volunteer involvement &
participation and to continue building a sustainable program.
Each spring the Lexington Appearance Commission (a City Council appointed
board) sponsors a "Cleaner City Campaign" to clean-up neighborhood streets,
parks, and public properties.
Building on its festival strength, and educating through participation, Lexington
recently sponsored a Recycling contest at a Summer Stroll event in its Uptown.
Youth ages 18 & under were invited to create two original artworks interpreting
the theme Recycle -Picture it. The event demonstrated artistic creativity and the
importance of recycling.
7.2.4 Evaluation of Effectiveness
The participation program measure will be evaluated on the number of
participants and physical measurements such as the amount of litter collected.
Once these items are quantified, metrics going forward can be established.
7.3 Illicit Discharge Detection and Elimination
The City of Lexington is concerned about the environment. Over the years, the
sanitary sewer system has been well maintained and monitored. A pre-treatment
and grease trap program is operated and inspections are conducted periodically.
The citizens and city employees call in problems when they see them. The City
will build on this strength to educate the citizens and its employees to watch for
illicit discharges. As Lexington's stormwater program evolves during this permit
period an effective program to detect and eliminate illicit discharges will be
developed.
Stormwater Management Plan — Page 18 of 26
NPDES Phase 11
7.3.1 BMP Summary Table
The following table outlines what best management practices the City of
Lexington will use in its illicit discharge program and the measurable goal.
Stormwater Management Plan — Page 19 of 26
NPDES Phase 11
BMP's and Measurable Goals for Illicit Discharge Detection and Elimination
BMP
s:Measurable Goals
1
Septic Tank Systems
Continue coordination with the County Health Department
regarding septic tank complaints
2
Sanitary Sewer Collection & Treatment Systems
Continue maintaining a responsible level of maintenance and follow
state regulations and guidelines for sanitary sewer treatment
3
Spill Response
Continue interdepartment coordination with Emergency Responders
to control hazardous waste spills
4
Recycling Program
Continue current levels of service and programs regarding
household waste collection, scrap tire removal
and white goods collection
5
Illicit Discharge Education
Continue information on Water Quality Report to advise public
on illegal/illicit discharges
7.3.2 Storm Sewer System Map
The City of Lexington is fortunate to have a GIS system. It has a drainage layer
that shows storm piping location and size, basins, and direction of flow. This
information was gathered by a City Surveyor in the past and digitized from mylar
maps. Other useful layers to name just a few include creeks and ponds, FEMA
flood information, USGS, lot ownership lines, and property information, aerials
and topos. The City's GIS is powered by information layers supplied from a
variety of Local, State, and Federal sources. The City GIS receives updates
nightly from the County and the City updates its layers of information as needed.
7.3.3 Regulatory Mechanism
To effectively prohibit illicit discharges during the permit period the City will
determine a course of action using ordinances.
7.3.4 Enforcement
The City of Lexington has Code Enforcement Officers that can be called upon as
needed, along with staff in the water and sewer utility that inspects grease traps
and pre-treatment facilities. Going forward the City will determine the best
approach to enforce ordinances.
7.3.5 Detection and Elimination
The City of Lexington owns and operates a sanitary sewer system regulated by
NCDENR. The Operator of Responsible Charge (ORC) is responsible for the
maintenance of the collection system. In the event of a sanitary sewer overflow
(SSO) care is given to follow proper reporting procedures and perform remedial
measures to prevent future occurrences. Routine maintenance techniques
include but are not limited to jetting 10% or more of the sewer lines each year
and subcontracting annual root control operations. The outfalls are inspected by
the crews and mowed to maintain accessibility. The City has a mainline sewer
camera and lateral camera that is used to routinely inspect sewer lines and also
check storm sewer lines when needed. Lexington has pre-treatment ordinances
Stormwater Management Plan — Page 21 of 25
NPDES Phase 11
to prevent heavy metals and toxic materials from entering the sewer system. A
grease trap policy and routine inspections reduce the amount of sewer stops.
Code Enforcement Officers are trained to spot illegal dumping. Water and Sewer
crews as well as Plant personnel in the course of their duties watch for unusual
activities/occurrences while maintaining the collection system and monitoring
what comes through the plant. Pre-treatment & grease trap inspections also
watch for illicit discharges.
Citizens call in sewer stops, septic tank issues (which the City reports to the
County Health Department) and drainage issues. The City will raise public
awareness to call in illicit discharges. This can be addressed by the tools
described in section 7.1 Public Education and Outreach.
7.3.6 Non-Stormwater Discharges
The City of Lexington does not identify and non-stormwater discharges or flows
as a significant contributor of pollutants to its storm system.
7.3.7 Occasional Incidental Non-Stormwater Discharges
The City of Lexington does not anticipate any occasional non-stormwater
discharges to its system.
7.3.8 Outreach
The City of Lexington plans to use educational materials and the water quality to
inform the public about the hazards associated with illicit discharges and
improper disposal of waste. Also, Channel 13, and the website product will be
used. The outreach plan to the public concerning illicit discharges will be an
integral part of both the public education and good housekeeping measures.
Stormwater Management Plan — Page 22 of 26
NPDES Phase 11
7.3.9 Staff Training
As mentioned in section 7.3.5 City staff currently reports unusual activities and
occurrences. During this permit period staff will be reminded to maintain
vigilance.
7.4 Construction Site Stormwater Runoff Control
Construction Site Stormwater Runoff Control in the City of Lexington is regulated
by:
NCDENR Winston-Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
(Main) 336-776-9800
(Fax) 336-776-9797
7.5 Post -Construction Storm Water Management in New Development
and Re -Development
The City of Lexington intends to develop a post -construction stormwater program
to manage post -construction discharges under NPDES Phase II requirements.
7.5.1 Regulatory Mechanism
The City of Lexington intends to develop a stormwater ordinance during the
allotted time in the permit period. It is anticipated that the model ordinance and
NCDENR's BMP manual will be largely followed.
7.5.2 Operation and Maintenance
The City of Lexington intends for its stormwater program to include an operation
and maintenance component that ensures the adequate long-term operation of
Stormwater Management Plan — Page 23 of 26
NPDES Phase 11
the structural BMPs required by the program. The program will require
inspections and require maintenance by the owner of the BMP.
The program shall be developed to control, to the maximum extent practical, the
sources of fecal coliform. The City provides and maintains a public sanitary
sewer system. For homes on septic tanks the County Health Department
ensures proper operation of the site wastewater treatment system.
7.6 Pollution Prevention/Good Housekeeping for Municipal Operations
The City of Lexington intends to identify and address good housekeeping issues
for its facilities and operation.
7.6.1 BMP Summary Table
The following table outlines what best management practices and measurable
goals the City of Lexington will use in its Pollution Prevention 1 Good
Housekeeping program.
Stormwater Management Plan — Page 24 of 26
NPDES Phase 11
BMP's and Measurable Goals for Pollution Prevention/Good Housekeeping for Municipal Operations
BMP
Measurable Goals
1 Employee Training
Assess current level of stormwater quality awarenes and emphasize
employee training to appropriate departments
2 Facility and Operational Assessment
Identify and address facility/operational needs
3 Spill Response
Continue interdepartment coordination with Emergency Responders
to control hazardous waste spills
4 Recycling Program
Continue programs regarding household hazardous waste collection,
scrap tire removal, and disposal of white goods
7.6.2 Affected Operations
The municipal operations of the City of Lexington that would be affected by this
program are Street, Recycling & Waste, Fleet, Recreation/ Public Grounds, Golf,
Public Buildings, Warehouse, Gas, Electric, Public Works M&C, Waste
Treatment Plant, Water Treatment Plant, Police, and Fire.
7.6.3 Training
The City intends to develop employee training to raise awareness and
prevent/reduce stormwater pollution.
7.6.4 Maintenance and Inspections
The City of Lexington makes a good effort to maintain its facilities. The City will
assess operational facilities with the intent of developing a list of measures to
improve housekeeping, storage and disposal of materials.
7.6.5 Vehicular Operations
This item is a continuation of section 7.6.4 to its outdoor facilities. As in the prior
section the City will assess the operational areas with the intent of developing a
list of measures to reduce/eliminate potential stormwater pollution.
7.6.6 Waste Disposal
The City of Lexington will examine its procedure and practices of waste disposal
with the intent to improve the operation as needed.
7.6.7 Evaluation of Effectiveness
The Pollution Prevention 1 Good Housekeeping measure will be evaluated by
identifying and implementing a list of improvements.
Stormwater Management Plan — Page 26 of 26
NPDES Phase 11
Water Quality Report
Best Tasting Water in NC in 1991 and 1995; Second Place in 2002
Information on Lexington's Drinking Water Produced in 2010
North Carolina Public Water Supply I.D. #NCO229010
This brochure is a summary of the quality of water provided by the City of Lexington to its customers from January I through
December 31 of 2010. It is a record reflecting the hard work of the employees involved in treatment and distribution of drinking water
and an affirmation of the City's commitment to provide a safe and reliable supply of water to its customers.
Sources of Lexington's drinking water: The Cities of Lexington and Thomasville
share Lake Thom-A-Lex as a water supply. It is classed as a surface water supply. The
take was constructed in the 1950's and has been the regular source of Lexington's
drinking water since then. The lake initially held 2.2 billion gallons of water. Since the
lake was built, silt has claimed less than 10% of its capacity. The City of Lexington has
installed an aeration system in the lower part of the lake to improve water quality.
In emergencies, the City has two emergency back up supplies: City Lake, which
contains about 150 million gallons of water, and several interconnections with Davidson
Water, Inc. Water must be pumped from City Lake to Lexington's Water Plants The
interconnections with Davidson Water, Inc. provide an opportunity for the two water
systems to support each other in emergencies.
Lexington's water is treated by two plants located on the same site off Old Greensboro
Road at Business I-85. The older plant was built in 1922 and has had several expansions
and upgrades over the years. The newer plant was built in
1967. Together, they are pumping an average of 3 million
gallons of water a day with the capability of pumping over
million gallons a day. Up to 3 million gallons of treated
water is stored at the water plants at any time. The quality
treated water from both plants exceeds state and federal
regulations.
Questions, Complaints, Emergency's:
-Emergencies:
after hours 248-2337
-Emergencies:
regular hours 248-3930
Questions:
regular hours 248-3970
-Website
www.lexingtonnc.net/
-Email:
rogers R.1exingtotinc.net
-Complaints:
regular hours 248-3970
Distribution System: City personnel maintain more than 187 miles of water lines, over 9,000 water meters, and 3 elevated storage tanks
holding up to 2 million gallons of treated water. Water meters are read and billed monthly.
Public comment is welcome at the regularly scheduled meetings of the Lexington Utilities
Commission and the Lexington City Council. The Utilities Commission has its regular
meeting on the first Monday of each month. Its meetings are held at Lexington's City Hall
located at 28 West Center Street starting at 7:00 P.M. The City Council has its regularly
scheduled meetings on the second and fourth Mondays of each month. Its meetings are held
at Lexington's City Hall starting at 7:00 P.M.
Water Conservation Tips:
-When you wash your car, park it in the grass, you'll wash the car and water the grass at the same time.
-Repair dripping faucets. If the faucet is dripping at the rate of one drip per second, you will loose 2,700 gallons of water in a year.
-Run the dishwasher and the clothes washer only when you have a full load. These appliances waste large volumes of water when run
partially loaded.
-The toilet uses more water than anything else in the house. Check for toilet leaks by periodically putting food coloring in the tank. If the
color shows up in the bowl without flushing, you have a leak which needs to be repaired. Do not use the toilet as a wastebasket. Put your
trash in the wastebasket.
-Set lawnmower blades I inch higher. Longer grass means less evaporation
-Mulch trees and plants to reduce evaporation
-Use a broom rather than a hose to clean your sidewalk or driveway
Wastewater Annual Reports: Reports of the operation of the City's wastewater treatment facilities are available for inspection by the
public at regular business hours. Call Roger Spach at 249-3970 for an appointment. These reports are also available on the City of
Lexington's website — www.Lexingtonnc.net
Maintaining
water meters
Lake
Thom-A-Lex
Special notice regarding lead in your drinking water:
If present, elevated levels of lead in drinking water can lead to serious health problems, especially for pregnant women and young
children. Lead in drinking water is primarily from materials and components associated with service lines and home plumbing. The City
of Lexington is responsible for providing high quality drinking water, but cannot control the variety of materials used in plumbing
components. When your water has been sitting for several hours, you can minimize the potential for lead exposure by flushing your tap
for 30 seconds to two minutes before using the water for drinking or cooking. If you are concerned about lead in your water, you may
wish to have your water tested (the City is not certified to do this testing). Information on lead in drinking water, testing methods, and
steps that you can take to minimize exposure is available at the Safe Drinking Water Hotline 1-800-426-4791 or at
http.epa.gov/safewater/lea&'.
Special Info Available: All sources of drinking water are subject to potential contamination by substances that are naturally occurring or
manmade. These substances can be microbes, inorganic or organic chemicals or radioactive substances. All drinking water, including
bottled water may reasonably be expected to contain at least some of these substances. The presence of these substances does not
necessarily mean that the water poses a health risk.
Some people may be more vulnerable to contaminants in drinking water than the general population. Immuno-compromised persons such
as persons with cancer undergoing chemotherapy, persons who have undergone organ transplants, people with HIV/AIDS or other
immune system disorders, some elderly persons and infants - can be particularly at risk from infections. These people should seek advice
about drinking water from their healthcare providers. Environmental Protection Agency and Centers for Disease Control guidelines on
appropriate means to lessen the risk of infection by Cryptosporidium are available from the EPA's Safe Drinking Water Hotline at 800-
4264791.
What's in your water? In order to ensure that tap water is safe to drink, EPA prescribes regulations which limit the amount of
certain contaminants in water provided by public water systems. These may be microbial contaminants, pesticides, herbicides,
organic chemicals and radioactive contaminants. Lexington's water met all state and federal standards for these. Below are
levels of these contaminants found in 2010.
test violation level average units MCLG MCL (*3) Source
YIN detected
Microblol2gical
Testing
Total Coliform(*4)
Fecal Coliform
Turbidity
Radiological
Testina
Alpha emitters
Beta/photon
emitters
Inorganic Testing
Barium
Copper
Fluoride
Lead
Nitrate
Oraanic Testin
N ND
0
<5% of
naturally present in the environment
samples
N ND
0
none
naturally present in the environment
N 0.04-0.29 0.09
NTU's
soil runoff
N ND
pCll
0
15
erosion of natural deposits
N 4.26
mrem/
0
50
erosion of natural deposits
year
N ND
NA
mgll
2
2
N 0.05-.251
0.125
mgll
1.3
1.3
(*2)
N 0.19 -
1.00
mg/l
4
4
1.40
N <3
<3
ppb
0
15
(*2)
N ND
NA
mg/l
10
10
drilling wastes; refineries;
natural deposits
corrosion and leaching of metal;
wood preservatives
natural deposits;
water treatment additive
corrosion of plumbing;
erosion of natural deposits
fertilizer; treated sewage,
erosion of natural deposits
2,4-D
N
ND
NIA
mg/l
0.007
0.007
herbicide
TTHMs (*1)
N
29 -124
63
ppb
0
80
by-product of drinking water chlorination.
1.4 —
HAA5 (*1)
N
91.5
42.9
ppb
0
60
by-product of drinking water chlorination.
IDSE TTHMs (*5)
N
27 — 118
56.8
ppb
0
80
by-product of drinking water chlorination
IDSE HAAY's (*5)
N
36.8 — 98.6
64.9
ppb
0
60
by-product of drinking water chlorination
Atrazine
N
0.00012
0.00012
mg/l
0.0002
0.003
pesticide
Dalapon
N
ND
N/A
mg/l
0.2
0.2
pesticide
Simazine
N
.0000092
.000092
mg/l
0.004
0.004 pesticide
Di(2-ethy1hexyl)phthalate
N
ND
NIA
mg/1
0
0.005
pesticide
Abbreviations: NO - not detected;
mg/l - milligrams
per liter;
ppb - parts per billion; pCll - picoCuries per liter
TTHM - total trihalomethanes;
HAA5
- haloacetic acids; mrems/year - millirems/year
* 1. Results reported as averages of 4 consecutive monitoring periods *2. Less than 10% of samples exceed the MCL. This defines
compliance. *3. MCL's (maximum contaminant levels) are very stringent. A person would have to drink two quarts of water a day at
the MCL level for a lifetime to have a one in a million chance of having the health effect ascribed to a contaminant. MCLC's (maximum
contaminant level goals) are levels of contaminants that are targeted levels to achieve. *4. 2 positive samples were collected, neither was
confirmed. *5. Special samples collected as part of a study to determine long term treatment needs
En Espanol. Para mas informaclon sobre el servicto de agua potable o para informacion sabre su cuenta de agua, por favor !lame a la
oflclna del Gerente de la cuidad durante horas de ojicina al telefono 248-3910.
3
Allow cooking grease to congeal and dispose of it in the trash instead of flushing it down the drain. Grease
will solidify in sewer lines to block them and cause them to overflow onto the ground and into streams!
The State of North Carolina published a Source Water Assessment Program Report in 2003 for the watersheds
providing Lexington's water supplies. Possible sources of contamination such as transportation incidents, chemical
spills, leaking underground storage tank sand old landfill sites were mentioned. For information on this, contact
Roger Spach at 336-248-3970 or rogers@lexingtonnc.net.
Protect your water supply and that of others! Storm drains do not discharge into the wastewater treatment
plant. They discharge into streams.
�. Chemicals, motor oil, trash, grass clippings, etc should not be dumped into storm drains
�y'' or in locations where they may be washed into ditches or streams. Eventually these will
Hr pollute the water supply of someone downstream of you.
' Be sure that your washing machine does not discharge into a creek. Its water must go
into your septic tank or into the sanitary sewer system
Silt from runoff and trash thrown out onto the ground are some of the major
contributors to pollution in High Rock Lake.
High Rock Lake is a recreation lake. Also, water from the lake enters public water
supplies all the way from its dam to where the Pee -Dee River enters the ocean. Please
make sure that what you do does not contribute to its pollution.
We at the City of Lexington work around the clock to provide top quality water to every tap. We ask all our
customers help us protect our water sources. These are the heart of our community, our way of life and our
children's future.
THE CITY OF ���' �z LEXINGTON
NORTH CAROLINA
f� CAR�V
"GROWING WITH THE PIEDMONT"
OFFICE FTHHL
CITY MANAGER
Coleen H. Sullins, Director
NCDENR
Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES Phase 11 Stormwater Program
Slate Designation Process
Dear Ms. Sullins:
February 14, 2011
15 2011
DENR - WATER QUAt.
Welundy 4 §!gWwa tt Bran!;
The intent of this letter is to provide relevant comments concerning .your letter dated
January,14, 2011, notifying the City of Lexington that we are under consideration for
inclusion in the NPDES Phase 11 Stormwater Program.
The background information attached to your letter indicates several programs and
actions that would be required under the Phase 11 designation and lists criterion that
effects the decision to determine our inclusion in the NPDES Phase 11 Stormwater
Program. The City of Lexington would like to offer the following information that we
feel should justify the City's position that we be excluded from the program. Please
consider the following:
Since early 2005, the City of Lexington along with Davidson County has elected
on our own accord to join the Stormwater Smart Program funded by its members
and managed and coordinated by the Piedmont Triad Council of Government
staff. This program provides strong public education and outreach activities
through middle and elementary schools, civic clubs, and the local scouting troops.
Brochures for wide distribution, newsletters for public buildings, and a website
are all part of the efforts to make the public more aware of the effects of
stormwater on the environment.
• The City of Lexington and Davidson County has employed the PTCOG to
develop a "Lower Abbotts Creek Local Watershed Plan." This is funded by a
federal 319 grant, a CWMTF grant, and local in kind match money (including in
kind contributions by the City to provide monitoring) totaling $255,994.
22 WEST CENTER STREET • LEXINGTON, NORTH CAROLINA 27292 • PH. 336-248-3910 • FAX 336-243-7371
Davidson County, with the assistance of the City of Lexington has adopted a
Master Greenway Plan that includes approximately 90 miles of primary routes,
many of which are along perennial streams. More importantly, Davidson County
applied for and received a $240,000 grant from the CWMTF to go towards the
establishment of a segment of greenway along Abbotts Creek. The County and
City are actively pursuing other grants to make this greenway a reality and serve
as a buffer to protect the impaired waters.
• Davidson County has received a Cleanwater Management Trust Fund grant for
$240,000. This is to provide for easement to produce a buffer of 300 feet on an
impaired section of Abbotts Creek. There is an additional $598,000 involved in
this for greenway construction, acquiring additional grants and in kind match
money from Davidson County and the City of Lexington. The easement is being
purchased on property owned by the City of Lexington for $184,000. Lexington
will turn this money back into the project and will partner with the County on the
greenway.
• The City of Lexington has constructed an on site reuse plant at its municipal golf
course which can provide up to 300,000 gallons per day of highly treated
wastewater to irrigate the golf course.
• The City has installed Biological Nutrient Removal facilities at its wastewater
treatment plant to remove both nitrogen and phosphorous from the effluent.
• Each year, the City publishes information on reducing stormwater pollutants on
its City Website and on the local cable channel.
• Each year, the City includes messages on reducing stormwater pollutants in both
its annual wastewater reports and its water quality reports. This information is
mailed to all of its 22,000 utility customers.
+ The City has enacted an extensive flood plain ordinance that has enabled the City
to obtain a class 7 with the FEMA National Flood Insurance Program
The City has installed and maintains a GIS mapping system, including the creeks
and tributaries.
• The City has developed a new land use ordinance with special provisions to keep
impervious areas to a minimum and provide stream buffers
• The City of Lexington employs a "Street Division" that maintains creeks and
storm drains along with debris removal from street grates.
The City of Lexington has a history of being proactive with its efforts to inform and
educate the public, regulate development, and promote water quality. Also, we have
2
increased our diligence after the designation of several of our streams as impaired. We
are confident that State's investigation will find that the City of Lexington does not
contribute to a violation of water quality, does not discharge contaminates into sensitive
waters, does not contribute to the pollution of water, and has implemented programs that
will continue to improve the quality of our waters.
The City of Lexington has been particularity hard hit during this economic slowdown.
Several factory closings have caused very high unemployment, loss of tax base, and
negative population growth. We strongly feel that the added cost associated with the
Phase 11 designation would be a huge blow to our currently weak economy.
Thank you for the opportunity to comment on the potential Phase H designation. If
further explanation of our comments is required, please let us know.
Sincerely,
ohn L. Gray
City Manager
Opz-tl SpA.w and , n t 5
i4'Cew.; LM s I 4 J
P&rry�d
3