HomeMy WebLinkAboutNCS000480_Rutherford College Draft SWMP v1_20191003Draft Stormwater Management Plan
Town of Rutherford College
NCS000480
September 27, 2019
Table of Contents
PART 1: INTRODUCTION.............................................,...............pot .............1
PART2: CERTIFICATION........................................................................................................................2
PART 3: MS4INFORMATION..... ..,:::.:: ,...:._.. ,....::. ......... ........ .....-::.........:3
3.1 Permitted MS4 Area..............................................................................................:............I........ ..3
3.2 Existing MS4 Mapping.................................................................................................................4
3.3 Receiving Waters.................................................................... ....... ...............................................9
3.4 MS4 Interconnection.....................,..............,...................... ...............9
3.5 Total Maximum Daily Loads(TMDLs)............................... ...... ...........10
3.6 Endangered and Threatened Species and Critical Habitat.......................................................a...11
3.7 Industrial Facility Discharges.....................................:...............................................................11
3.8 Non-Stormwater Discharges .............................. ................... ........... ..........,..:..:.::........,..............12
3.9 Target Pollutants and Sources.....................................................................................................13
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION...................................17
4.1 Organizational Stmcture.......................................................add ...... ...... ......... .. ............ ........ ........ $17
4.2 Program Funding and Budget ..................................... .............>......................................I...........119
4.3 Shared Responsibility....... ......... III .:..... „ I a I I' Ph a . ...:.... . ,..... , 1 ......M19
4ACo-Permittees.:....................:..............:............:......:............:..:..........:.....:.......:..I..::..:....I.. I. I.I.....21
4.5 Measurable Goals for Program Administration.......................................................................... 21
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM.........................................................23
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION FROGRAM..............................32
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM...................................................42
PART
10:
POLLUTION PREVENTION
AND GOOD HOUSEKEEPING PROGRAMS .......................57
List of Tables
Table 1:
Summary of MS4 Mapping
Table
2:
Summary of MS4 Receiving Waters
Table
3:
Summary of Approved TMDLs
Table
4:
Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Table
5:
NPDES Stormwater Permitted Industrial Facilities
Table
6:
Non-Stormwater Discharges
Table
7:
Summary of Target Pollutants and Sources
Table
8:
Summary of Responsible Parties
Table
9:
Shared Responsibilities
Table
10:
Co-Permittee Contact Information
Table
11:
Program Administration BMPs
Table
12:
Summary of Target Pollutants & Audiences
Table
13:
Public Education and Outreach BMPs
Table
14:
Public Involvement and Participation BMPs
Table
15:
Illicit Discharge Detection and Elimination BMPs
Table
16:
Qualifying Alternative Program Components for Construction Site Runoff Control Program
Table
17:
Construction Site Runoff Control BMPs
Table
18:
Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program
Table
19:
Summary of Existing Post -Construction Program Elements
Table
20:
Post Construction Site Runoff Control BMPs
Table
21:
Pollution Prevention and Good Housekeeping BMPs
PART 1: INTRODUCTION
The purpose of this Stormwater Management an (SWMP) is to establish and define the means by which
the Town of Rutherford College will comply with its National Pollutant Discharge Elimination System
(NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the
Clean Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum
extent practicable.
This SWMP identifies the specific elements and minimum measures that the Town of Rutherford College
will develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental
Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with
the MS4 Permit number NCS000480, as issued by NCDEQ. This permit covers activities associated with
the discharge of stormwater from the MS4 as owned and operated by the Town of Rutherford College and
located within the corporate limits of the Town of Rutherford College.
In preparing this SWMP, the Town of Rutherford College has evaluated its MS4 and the permit
requirements to develop a comprehensive 5-year SWMP that will meet the community's needs, address
local water quality issues and provide the minimum measures necessary to comply with the permit. The
SWMP will be evaluated and updated annually to ensure that the elements and minimum measures it
contains continue to adequately provide for permit compliance and the community's needs,
Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along
with any approved modifications of the SWMP, are incorporated by reference into the permit and become
enforceable parts of the permit.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 21, 20N
Page 1
PART 2: CERTIFICATION
By my signature below I hereby 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 gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete.
I am aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations.
I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4
Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit
compliance and enforcement authority.
® I am a principal executive officer or ranking elected official.
❑ I am a duly authorized representative and have attached the authorizafion made in writing by a principal
executive officer or ranking elected official which specifies me as:
❑ A specific individual having overall responsibility for stormwater matters.
❑ A specific position having overall responsibility for stormwater matters.
Signature:
ti G �
Name:
Kenneth Geathers
Title:
Town Manager
Signed this 3s day of September 201
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 201Y
Page 2
PART 3: M34 INFORMATION
361 Permitted MS4 Area
This Stormwater Management Plan (SWMP) applies throughout the corporate limits of the Town of
Rutherford College, including all regulated activities associated with the discharge of stormwater from the
MS4. The map below shows the corporate limits of Town of Rutherford College as of the date of this
document.
DRAFT NC5000480 SWMP
Town of Rutherford College
September 27, 2019
Page 3
392 Existing MS4 Mapping
The current MS4 mapping includes all required elements for compliance. Below are a series of maps that
show the locations of the catch basins, junction boxes, and drainage manholes within the City Limits.
(Reference BMP 19),
DRAFT NCS000480 SWMP
Town of Rutherford College
September 2 Y , 2019
Page 4
To\vn of Rutherford College Stormwater P
(Map 2 of 3)kr
R
.ow�
HO
` ICI lllY►Plk14
it
y
104
�I aid IIL
gg TA
LIT k
pm Ilk
M1 o
GpAD ST
_� i i- t t ��flt`.1M211e ST •i1�
Legend
Rutherford College Taws Limits
Slam Drain Pipe
�- Streams l Rivers
Roads
❑ Catch Basin
Possible Junction Box N
0 ISO 300 Feet
li ili it �1
Valdese
Town L-Wts N
0 0 •�
tJ C t for Cledt� ph'c lnrwna onn'6 AnCCNdIIUrwa�As�s
DRAFT NCS000480 5WMP
Town of Rutherford College
September 21, 2019
Page 5
Town of Rutherford College Stormwater hs
(Map 3 of 3)14
ir
�\
SPAVARD sr �,K
i _
rST
4 rp
FF
10
4 W
r CR&SUS r M1 _ ,pe. _ G
Z1r1i4 I ao �' -
41
?� RAMSEy sT i
r----__— _I BOYD sT T/
44
III GREENSri ,,P�ISGfLIA CR
TUYtt@aow8r�
c
III- I
LOWMANST II:I- ��§Q@CKNELI ST .._
�i us vo
r-_ 70F_
IL
r I i
Legend I ,-
{� �,,:
Rutherford College Town Limits
as
it Rutherford College ETJ •�• y ag
.;' Stome Drain Pipe
Streams 1 Rivers \\\\
Roads' f 'a
❑ Catch Basinry
10
Drainage Manhole F-Ali
Possible Junction Box N 4
r r
0 250 500 Feet�r
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 20A
Page 6
The following set of maps show the direction of now and the major outfalls within Rutherford College
Town limits. Further mapping is outlined in BMP 19,
A f fe
1 1
-40
s�=
oW�
goo'
0
zpNm
3
O
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 7
W
(7
W
J
J
�a0
z
Owz
Z
rc¢0
= 3 uUl
7�W
pNm
Z
O
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 8
Table 1: Summary of MS4 Mapping
Percent of MS4 Area Mapped 90
No, of Major Outfalls* Mapped 29 total
*An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditc72) directly
into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major
outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned
areas a 12-inch diameter pipe or a drainage area > 2-acres.
3.3 Receiving Waters
The Town of Rutherford College MS4 is located within the Catawba River Basin and discharges duectly
into receiving waters as listed in Table 2 below. Applicable water quality standards listed below are
compiled from the following NCDEQ sources:
o Waterbody Classification Map
o Impaired Waters and TMDL Map
o Most recent NCDEQ Final 303(d) List
Table 2: Summary of MS4 Receiving Waters
Receiving Water Name
Stream
Water
303(d) Listed Parameters)
Index / AU
Quality
of Interest
Number
Classification
Catawba River
l l-(37)
WS-IV, B,
n/a
CA
Hoyle Creek
11-45-(0.5 &
WS-IV, CA
n/a
2)
Island Creek
11-46-(0.5)
WS-IV, CA
n/a
Smith Branch
11-46-1
WS-IV
n/a
3.4 MS4 Interconnection
The Town of Rutherford College MS4 is interconnected and drrectly receives stormwater from the Town
of Valdese MS4 (reference BMP 19); however the Town of Rutherford College MS4 does not directly
discharge stormwater into another MS4.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 9
3.5 Total Maximum Daily Loads (TMDLs)
The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map
and list provided on the NCDEO Modeling & Assessment Unit web page. The table also indicates
whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed
directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program
has been implemented to address the WLA. Outreach education and stream cleanup helps with the
reduction of waste load allocation within approved TMDL municipalities.
Table 3: Summary of Approved TMDLs
Water Body Name
TMDL Pollutants)
Stormwater
Water
Waste
Quality
Load
Recovery
Allocation
Program
(Y/N)
(Y/N)
N/A
N/A
N
N
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 10
3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or critical habitat are identified within the
regulated MS4 urbanized area, as determined by a review of the Endangered and Threatened Species and
Species of Concern by County for North Carolina Map and Listed species believe to or known to occur in
North Carolina map as provided by the U.S. Fish and Wildlife Service. Of those species listed, Table 4
summarizes the species that may be significantly impacted by the quality of surface waters within their
habitat.
Table 4; Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Scientific Name
Common name
Species Group
Federal Listing
Status
Glyptemys
Bog Turtle
Vertebrate
T (S/A)
muhlenber ii
Glaucomys sabrinus
Carolina northern
Vertebrate
E
coloratus
flying squirrel
Myotis septentrionalis
Northern long-eared
Vertebrate
T
bat
Corynorhinus
Virginia big -eared bat
Vertebrate
E
townsendii
vir inianus
Alasmidontavaricosa
Brookfloater
Invertebrate
ARS
Ophiogomphus
Edmons's Snaketail
Invertebrate
ARS
edmundo
Macromia margarita
Margarita River
Invertebrate
ARS
skimmer
Microhexura
Spruce -fir moss
Invertebrate
E
montiva a
spider
Hexastylisnanii fora
Dwarf -flowered
Vascular Plant
T
heartleaf
Liatris helleri
Heller's blazing star
Vascular Plant
T
Hedyotis purpurea
Roan Mountain Bluet
Vascular Plant
E
var. montana
3.7 Industrial Facility Discharges
The Town of Rutherford College MS4 jurisdictional area includes the following industrial facilities which
hold NPDES Industrial Stormwater Permits, as determined from the NCDEQ Active NPDES Stormwater
Permit List and/or Active Stormwater Permits Map.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 11
Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number Facilit Name
NCG170393 A uafil O'Mara Inc.
NCGNE0258 BSN-Jobst, Inc.
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the Town of Rutherford
College as summarized in Table 6 below. The unpermitted non-Stormwater flows listed as incidental do
not significantly impact water quality. The Town of Rutherford College has evaluated residential and
charity car washing and street washing for possible significant water quality impacts.
Streetwashing discharges are addressed under the Pavement Management Frogram in Part 10 of this
SWMP. The Department of Environmental Quality has not required that other non-stormwater flows be
specifically controlled by the Town of Rutherford College.
Wash water associated with car washing that does not contain detergents or does not discharge directly
into the MS4 is considered incidental. However, these types of non-stormwater discharges that do
contain detergents/surfactants have been evaluated by the Town of Rutherford College to determine
whether they may significantly impact water quality. The Town of Rutherford College will address the
possibility of the below mentioned water quality impacts through public education and good
housekeeping, as outlined in Part 5, BMP 3-7. and Part 10 BMP 45-479 49, 53, 54, 56, 57 and 61 with a
focus on the training of good housekeeping practices.
Table 6: Non-Stormwater Discharges
Non-Stormwater Discharge
Water uali hn acts
Water line and fire hydrant flushin
Incidental
Landscape irrigation
Incidental
Diverted stream flows
Incidental
Rising groundwater
Incidental
Uncontaminated groundwater infiltration
Incidental
Uncontaminated pumped groundwater
Incidental
Uncontaminated potable water sources
Incidental
Foundation drains
Incidental
Air conditioning condensate
Incidental
Irrigation waters
Incidental
Springs
Incidental
Water from crawls ace pumps
Incidental
Footing drains
Incidental
Lawn watering
Incidental
Residential and charity car washing
Possible
Flows from riparian habitats and wetlands
Incidental
Dechlorinated swinaming pool discharges
Incidental
Street wash water
Possible
Flows from firefighting activities
Incidental
DRAFT NC5000480 5WMP
Town of Rutherford College
September 27, 2019
Page 12
3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the Town of Rutherford College is not aware of
other significant water quality issues within the permitted MS4 area.
Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the
likely activities/sourceshargeted audiences attributed to each pollutant, and identifies the associated
SWMP program(s) that address it. In addition, the Town of Rutherford College has evaluated schools,
homeowners, construction sites and businesses as target audiences that are likely to have significant
stormwater impacts.
Within the table below the following target pollutants have been commonly found to be concerns within
the community.
Litter: Illegal dumping has occurred within the Town.
Cases general residential dumping have been noted by Town employees. This litter poses a threat to both
our water bodies and the MS4 infrastructure, as the litter can create clogs and backups that damage the
pipelines leading back to the stream. Some litter even poses a threat to groundwater if chemical leaching
or breakdown of components into heavy metals occurs due to weathering of the litter. The dumping has
been found typically road side but also in secluded urban areas.
Sediment: Previous installed erosion control measure have been removed or fallen
Sediment buildup is largely attributed to mismanaged construction sites with fallen or incorrectly installed
sediment fences. It has been noticed in bothreports from Citizens and by code enforcement officers that
there are several cases of construction sites not maintaining their erosion control fences during work. This
has led to sediment buildup near storm drains, onto down slope private properties, and in some cases
causing water to build up in nearby properties as the sediment is limiting the drains ability to remove
runoff. In all cases code enforcement has responded and had the issue solved, but even being down for a
short time can prove to have significant effects. Erosion control fences are required for sediment control
permits during construction by the DEQ throughout the entire construction process.
Gray Water: Straight piping washing machines out of the house
Rarely, it has been noted a few homes have had their washing machines straight -piped out of their homes
by creating makeshift piping using water hoses. exit at windows. Homes are to be connected to the
appropriate sewer system. This proves to be a source of detergents/soaps entering our storm drains in
residential neighborhoods. In addition: residential, charity, and municipal car washes allow for soaps or
waxes to enter the storm drain when vehicles are not being cleaned in the correct areas (such as vegetated
patches or in areas that do not have storm drains). This allows for toxic contaminants to enter our
waterways via the storm drain system.
Fats Oils and Grease: Restaurants could possibly empty grease traps or not obtain a grease trap.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 13
The Health Department has reported restaurants not maintaining, or even owning, grease traps. This has
led to cases of the restaurants either illegally dumping the grease or allowing the grease to drip onto
nearby impermeable surface — which would eventually lead to water quality issues. Overflow from a lack
of maintenance or throwing out the grease with general waste contributes to this problem. This is a health
violation since the grease poses a physical risk, but it also can impair water bodies with an influx of water
insoluble grease going down the storm drain.
Chemicals: Totes have been noted in industrial areas, which could pose a risk.
Town staff have noticed containers within manufacturing facilities that have unmarked chemicals. The
totes are unlabeled in select industrial sites, leading to potential soil and water contamination, and/or
incorrect spill cleanup procedure. In addition to not labeling the containers correctly, the Town has noted
that the containers are not being correctly stored in a way to minimize risk to the water bodies from
seepage, damage to the containers, or spills.
Animal Operations/Urban Farming: A challenge to ensuring water quality for several factors.
Animal operations are agriculture operations that raise cows, pigs, chickens, or other livestock as a
product, be it from meat or byproducts of the animal, the latter being more problematic as the excess
nutrients will lead to eutrophication which can eventually causing hypoxia in the water body. In a similar
vein, agricultural runoff often canes excess fertilizer which also will cause eutrophication in streams with
its cascading effects. Within the Catawba River Basin roughly 46 streams are/were impacted by fecal
coliform, with 10 being listed on the 303(d) list. As this is a non -point source pollutant it is hard to locate
the exact source of this runoff, however in much of the watershed there is agricultural zoning that makes
it likely for these types of impairments to occur. Roughly 20% of land use within the basin is agricultural.
Urban farming is a common theme within the Town. Upon meeting appropriate requirements one can
obtain a zoning permit to allow farm -like animals. The same holds true as animal operations, but to a
lesser scale, the excrement and ground disturbance can impact the water quality.
Underground storage tanks: SEorage devices installed below ground that contain hazardous
materials/waste.
These tanks can contain gasoline,. fuels such as propane, industrial chemicals/oIls, and most often human
waste in areas not directly connected to the sanitary sewer. Any underground storage tank must be well
maintained/monitored, and correctly installed due to the risk of them leaking. The leaks can cause
whatever chemical the tank is storing to leak into the ground, harming the soil, groundwater/water table,
and even surface waters as they are being fed from groundwater. If a fuel or industrial chemical tank is
leaking, the chemical will leach into the soil — leading to toxic soil, contaminated groundwater, and
possibly impairing a stream/water body. If a septic tank is leaking, it can overwhelm the natural processes
of the soil (infiltration) leading to nutrient overload in streams fed by groundwater, or allowing pathogens
to enter, increasing the risk of disease. The 10 303(d) fecal coliform impaired streams listed can have
some attribution to septic tank leakage.
Illicit discharges: Originate from a variety of sources, with an equally varied number of effects
dependent on the chemical that is released.
DRAFT NC5000480 SWMP
Town of Rutherford College
September 27, 2019
Page 14
Typically, illicit discharges come from businesses, residents or municipal facilities who dump chemicals
into storm drains either incidentally due to a lack of Illicit Discharge & Detection Elimination (IDDE)
education or general carelessness. These chemicals can vary greatly, and can include grease, oils,
chemicals, cleaning solutions, paints, metals, etc. This is a recognized problem as we have several 303(d)
streams impaired from causes related to substances or attributions given to unclean discharges into the
streams - in addition to reports generated by the municipality. Many of the 303(d)benthos impaired
streams can be attributed to IDDE issues, but they are often from inexact/non-point sources that are
attributed to illicit discharges
Illegal dumping: When residents, businesses, or municipal employees dump waste randomly in
non -permitted dumping areas.
This waste can widely vary, causing a variety of problems. For example, citizens dumping televisions on
the side of the road to avoid dumping fees, which allows for the metals or chemicals inside the tv to leach
out as stormwater passes it (mercury, lead, and other metals). It can be a case of businesses dumping
waste in watershed areas where runoff passes through the waste, either carrying it, or residuals of the
waste into water bodies. It can also be a case of graders dumping sediment into areas without the correct
allowances/precautions. The debris and chemicals accumulate over time and lead to chemical
impairments, pH issues, turbidity impairments, or debris entering the stream/MS4 system.
Improper disposal of waste:
Improper disposal of waste is problematic because it allows chemicals, or difficult to manage waste, to
enter the environment in ways that may be hard to track. For example; not giving a car battery to the
correct waste management facility can allow for battery acid and lead to enter the soil which
drains/collects in the groundwater. This problem has been noticed by municipal waste managers and is
difficult to track as often the improper disposal waste is mixed in with the standard refuse. Other
examples include grease going down sinks clogging MS4 systems, chemicals from batteries leaching into
the groundwater, oil from oil changes not going to the correct facility, etc.
Table 7: Summary of Target Pollutants and Sources
Target Pollutant(s)
Likely Sources)/Target Audiences)
SWMP Program Addressing
Tar et Pollutants)/Audience(s)
Litter
Residents, Businesses, Schools
Public Education & Outreach
Public Participation
Sediment
Construction Activity
Public Education & Outreach,
Construction Program
Post -construction Program
Gray water
Residential
Illicit Discharge
Public Education & Outreach
Fats, Oils and Grease
Businesses (Restaurants)
Illicit Discharge
Public Education & Outreach
Chemicals
Industrial, Business and Residential
Illicit Discharge
Public Education & Outreach
Good Housekeeping
DRAFT NC5000480 SWMP
Town of Rutherford College.
September 2I, 2019
Page 15
Animal Operations
Commercial/Bona fide Farms/Urban
Illicit Discharge
Farming
Public Education
&
Outreach
Underground Storage Tanks
Business and Residents
Illicit Discharge
Public Education
&
Outreach
Illicit Discharges
General Public, Businesses,
Illicit Discharge
Municipal Employees
Public Education
&
Outreach
Good Housekeeping
Illegal Dumping and
General Public, Businesses,
Illicit Discharge
Improper Disposal of Waste
Municipal Employees
Public Education
&
Outreach
Good Housekeeping
DRAFT NCS000480 SWMP
Town of Rutherford College
September 21, 2019
Page 16
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 OrganizationalStructure
The Town of Rutherford College has contracted Western Piedmont Council of Governments (WPCOG7
to coordinate Stormwater Management Plan development/writing efforts, to ensure the Town is
facilitating Best Management Practices to protect water quality. The Town of Rutherford College will be
the primary operator of this stormwater program. Staff will be trained in handling internal procedures and
reports of stormwater issues/violations. WPCOG be implementing the Public Education & Outreach, and
the Public Involvement & Participation on behalf of the Town. The following organizational chart is
broken down by the six elements associated with Stormwater Management. Each of the positions under
the elements will report back to the primary manager and then on to the Stormwater Program
Administrator,
Sarrnwa[er Prigram Atlminklmtor
)Town Manager)
Aormwxer Management (Admink[mtar)
Public Education
andontrexh
Pudic Involvement
and Particl�h'on
IIIicROkcharge DRedion
and EAminetion
SRe
PoSRurtoRContml
PWIWon PrevermoN
GounHoal Opepithim
Municipal operation
WPCOG Senior Plen�mr/ WPCW tar Dlanner/ own of RUFM1erford TownofRutherford Townof Rutherfortl COF Town oFRutherford
oral Resource Natural Mamoru college Dublic Works CalAdinfromiwater legs Publicwes0 (Good mse Works
H AdmNinmtor Adminisdmtor (Enforcement) Atlmmutmtor (Municipal Eacllltlesopx- (Good Housekeeping
ram- MaintenancePro- Educator)
grem-OYand;W on and
RepoNig;TMGL
TovneERuiherfard requlnemenrl
College Public Warks
(Educator)
Town Employee
MM Operation& Maintenance
Municipal WM Gpembon and
Maintenance
Vehicle at Equlpmentclmning
Pavement ManagemeR
pesticides, Herbicide & EeMlleer
Management
Table 8: Summary of Responsible Parties
SWMP Component
Responsible Position
Staff Name
Department
Town Manager
Kenneth Geathers
Administration, Town
Stormwater Program
of Rutherford College
Administration
Town Manager
Kenneth Geathers
Administration, Town
SWMP Management
of Rutherford College
Public Education &
WPCOG Senior
Johnny Wear
WPCOG, Community
Outreach
Planner/Natural
and Regional Planning
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 17
Resources
Administrator
Public Involvement & WPCOG Senior Johnny Wear WPCOG, Community
Participation Planner/Natural and Regional Planning
Resources
Administrator
Illicit Discharge Utility Director John Leger Town of Rutherford
Detection & College Public Works
Elimination
Construction Site N/A N/A NCDEQ — Asheville
Runoff Control Regional Office
Town Manager
Kenneth Geathers
Town of Rutherford
Post-Constmcuon
College
Stormwater
Management
Utility Director
John Leger
Town of Rutherford
Pollution
College Public Works
Prevention/Good
Housekeeping for
Municipal Operations
Municipal Facilities
Utility Director
John Leger
Town of Rutherford
Operation &
College Public Works
Maintenance Program
Spill Response Program
Utility Director
John Leger
Town of Rutherford
College,
Volunteer/Town Fire
Department, if
MS4 Operation &
Maintenance Program
Utility Director
John Leger
Town of Rutherford
College Public Works
Municipal SCM
Utili[y
Director
John
Leger
Town of Rutherford
Operation &
College Public Works
Maintenance Program
Pesticide, Herbicide &
Utility
Director
John
Leger
Town of Rutherford
College Public Works
Fertilizer Management
Program
Utility
Director
John
Leger
Town of Rutherford
Vehicle & Equipment
College Public Works
Cleaning Program
Utility
Director
John
Leger
Town of Rutherford
Pavement Management
College Public Works
Program
DRAFT NCS000480 SWMP
Town of Rutherford College
September 21, 2017
Page 18
N/A
N/A
N/A
Total Maximum Daily
Load (TMDL)
Requirements
4.2 Program Funding and Budget
In accordance with the issued permit, the Town of Rutherford College shall maintain adequate funding
and staffing to implement and manage the provisions of the SWMP and comply with the requirements of
the NPDES MS4 Permit. The budget includes the permit administering and compliance fee, which is
billed by DEQ annually.
As mentioned previous, WPCOG was contracted to write the Town of Rutherford College's Stormwater
Management Plan, for a rate of $8,000.00. Also, the Town has a one-year contract (which will need to be
modified, adopted, and signed every year) with Western Piedmont Council of Governments for the
following services: Public Education & Outreach Program and Public Involvement & Participation
Program. The current one year contract (July 1, 2019 and ending June 30, 2020) amount is $2,845.00,
The Town of Rutherford College will be using Town staff, and on occasion West Consultants, to
implement Illicit Discharge Detection and Elimination Program, Post -Construction Site Runoff Control
Program, and Pollution Prevention and Good Housekeeping Programs. The Town has allocated
$11,500.00 toward this effort.
The Town will be responsible for the cost of the annual NPDES permit renewal, which is to be paid to the
state. Any fees charged to the development community for BMP Inspections, Plan Review, and other
associated fees will help offset this cost to the town. The Town reserves the right to apply stormwater
utility fees to supplement stormwater management costs; these fees would be collected by the Town
through tax or utility bills. The goal would be for the funds collected to support the stormwater program
through stream repairs and other water quality efforts.
Should the Town of Rutherford College choose not to renew the existing one-year contract with WPCOG,
prior to the last month, a revision to the existing NPDES permit and Stormwater Management Plan would
need to occur. The Town of Rutherford College would be required to renew the one-year contract for five
years straight to fully carry out the 5 year NPDES permit cycle. Any changes to the partners or measures
in this document will need to be reviewed and approved by NCDEQ.
4.3 Shared Responsibility
The Town of Rutherford College will be responsible to implement the following minimum control
measures, with the aid of WPCOG (entity)., which are as stringent as the corresponding NPDES MS4
Permit requirement. The Town of Rutherford College remains responsible for compliance if the other
entity fails to perform the permit obligation and may be subject to enforcement action, if neither the Town
of Rutherford College, nor the other entity fully performs the permit obligation. Table 9 below
summarizes individual responsibilities for each program.
DRAFT NCS000480 5WMP
Town of Rutherford College
September 21, 2019
Page 19
Table 9: Shared Responsibilities
Legal
SWMP BMP or
Implementing Entity & Program Name
Agreement
Permit Reference
(Y/1)
General Requirements
Town of Rutherford College
N
Public Education and
WPCOG Stormwater Partnership
Y
Outreach Program
Public Involvement and
WPCOG Stormwater Partnership
Y
Participation Program
Elicit Discharge Detection
Town of Rutherford College
N
and Elimination Program
Construction Site Runoff
NCDEQ
N/A
Control Program
Post -Construction Site
Town of Rutherford College
N
Runoff Control Program
Pollution Prevention and
Town of Rutherford College
N
Good Housekeeping
Programs
Total Maximum Daily Load
N/A
N
DRAFT NCS000480 SWMP
Town of Rutherford College
September 275 2019
Page 20
4.4 Co-Permittees
There are no
other entities
applying for co-permittee status under the NPDES MS4 permit number
NCS000480
for the Town
of Rutherford
College,
4.5 Measurable Goals for Program Administration
Referencing, MS4 Inspection Report for the Town of Rutherford College -Program Implementation,
Documentation & Assessment, Permit Citation - II.A.2. Stormwater Plan Implementation & Evaluation,
II.A.3. Keeping the Stormwater Plan Up to Date, II.A.4. Availability of the Stormwater Plan, H.A.S.
Stormwater Plan Modifications and II.A.7 Written Procedures; the Town has not evaluated the
performance and effectiveness of the program and has not develop any procedures for doing so. In order
to meet the State requirements for this section, a self -assessment of the effectiveness of the program
components will be completed annually. Written procedures, otherwise known as, the Stormwater
Management Plan: SWMP update, has been drafted, but not adopted at this time. The SWMP will be
adopted during Permit Year One of the NPDES permit cycle following acceptance of the SWMP and
issuance of the NPDES permit. Included in the SWMP the Town will be required to establish written
agreements with entities that are performing work on the Town's behalf (B.A.6.).
MS4Inspection Report for the Town of Rutherford College -Program Implementation, Documentation
Assessment, Permit Citation - III.A. Program Documentation; the Town maintained some documentation
regarding inspections, but no other aspect of the program components. There was an overall lack of
documentation relating to the Town's stormwater program (e.g., no documentation for inspections,
maintenance activities, or educational programs).
MS4 Inspection Report for the Town of Rutherford College -Program Implementation, Documentation &
Assessment, Permit Citation-111.B. Annual Report Submittal: M34 annual reports have not been
submitted. Further, no fiscal analysis was provided (Permit Citation - IV.B). Within the below BMPs
Annual Report are a required submittal that will occur on August 31' each permit year and will include
all applicable parts of the NPDES MS4 permit.
The Town of Rutherford College will manage, document, and report the following Best Management
Practices (BMPs) for the administration of the Stormwater Management Program using Public. Education
& Outreach, Public Involvement & Participation, Illicit Discharge Detection & Elimination, Post -
Construction Site Runoff Control, and Pollution Prevention & Good Housekeeping.
Table
11: Program Administration BMPs
Permit
2.1.2 and Part 4: Annual Self -Assessment
Ref.
Measures to evaluate the performance
and effectiveness of the SWMP program components
at least annually.
Results shall be used by the permittee
to modify the program components as necessary to
accomplish the intent
of the Stormwater Program, The self -assessment
reporting eriod is the fiscal year (Jul
1 — June 30).
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
I
Annual Reporting
Metric
DRAFT N0S000480 SWMP
Town of Rutherford College
September 27, 2019
Page 21
Table 11: Program Administration BMPs
1.
Annual Self -Assessment
Perform an annual evaluation of
1. Prepare, certify,. and
1. Annually for Permit
1. Annual Self-
SWMP implementation,
submit the Annual Self-
Years 1-4
Assessment received by
suitability of SWMP
Assessment to NCDEQ
(FY19/20 — FY22/23)
NCDEQ no later than
commitments and any proposed
prior to August 31 each
August 31 each year.
changes to the SWMP utilizing
year.
the NCDEQ Annual Self -
Assessment Template,
Permit
1.6: Permit Renewal Application
Ref.
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit,
A
B
C
D
BMP
Noe
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
2.
Permit Renewal Application
Audit stormwater program
1. Participate in an
1. TBD — Typically
L N/A
implementation for compliance
NPDES MS4 Permit
Permit Year 4
with the permit and approved
Compliance Audit, as
SWMP, and utilize the results to
scheduled and performed
(FY22/23)
submit
prepare and submit a permit
b EPA or NCDEQ.
2• Self -audit and
2. Permit Year 5
2, Submit Self -Audit to
renewal a ica package.
document any
DEMLR (required
stormwater program
(FY23/24)
component of permit
components not audited
renewal application
by EPA or NCDEQ
package).
utilizing the DEQ Audit
Tem late.
3. Certify and submit the
3. Permit Year 5
3. Permit renewal
stormwater permit
application package
renewal application
(FY23/24)
received by DEQ at least
(NOI, Self -Audit, and
180 days prior to permit
Draft SWMP for the next
expiration.
5-year permit cycle).
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 22
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The Town of Rutherford College will implement a Public Education and Outreach Program (developed
by and programs ran by WPCOG) to distribute educational materials to the community or conduct
equivalent outreach activities about the impacts of storm water discharges on water bodies and steps the
public can take to reduce pollutants in storm water runoff.
In reference to MS4 Permit Self Audit Report -Public Education and Outreach, Permit Citation II.B.2.a
Program Requirements, I1.13.2.c. Target Audience's, and 11.13.21. Public Education and Outreach
Program: The Town of Rutherford College had not defined goals & objectives for community wide
issues. Stormwater impact target audiences and extend of exposure had not been recorded at public
education and outreach events.
The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by
the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the Town of
Rutherford College is required to inform businesses and the general public of the hazards associated with
illicit discharges, illegal dumping and improper disposal of waste.
Table 12: Summary of Target Pollutants &Audiences
Tar et Pollutants/Sources
Tar et Audiences)
Litter
Residents, Businesses, Schools
Sediment
Construction Activity
Gray water
Residential
Fats, Oils and Grease
Businesses (Restaurants)
Animal operations
Commercial, Bona fide Farms and/or Urban Farming
Underground Storage Tanks
Businesses and Residents
Chemicals
Industrial, Business and Residential
Illicit Discharges
General Public, Businesses, Municipal Employees
Illegal Dumping
General Public, Businesses, Municipal Employees
Improper Disposal of Waste
General Public, Businesses, Municipal Employees
The WPCOG (on behalf of the Town of Rutherford College) will manage, implement and report the
following public education and outreach BMPs.
Table 13: Public Education and Outreach BMPs
Permit
3.2: Outreach to Targeted Audiences
Ref.
Measures to identify the specific elements and implementation
of a Public Education and Outreach Program to
share educational materials to the community or conduct equivalent outreach activities about the impacts of
stormwater discharges on water bodies and how the public can
reduce pollutants in stormwater runoff. The
permittee shall document the extent of exposure of each media,
event or activity, including those elements
implemented locally or through a cooperative agreement.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 23
Table 13: Public Education and Outreach BMPs
3.
Stormwater Fliers
Stormwater fliers will be
1. Develop and
1. Permit Year 1
1-5, Document and
distributed to Town residences,
distribute
report the topic and
municipal employees, businesses,
fliers at Town
(FY19/20)
number of flyers
and industrial facilities through
event to create
distributed at each
Stormwater events. Five topics
stormwater
event,.
will be addressed over the term of
awareness,
2. Develop and
2. Permit Year 2
the permit; general stormwater
awareness, illicit discharges,
distribute a
illegal dumping, chemicals, and
fliers for illicit
(FY20/21)
proper disposal of waste.
discharges.
3. Develop and
3. Permit Year 3
distribute a
fliers for
(FY21/22)
illegal
dumping.
4. Develop and
4. Permit Year 4
distribute
fliers for
(FY22/23)
chemical
awareness.
5. Develop and
5. Permit Year 5
distribute
fliers for
(FY23/24)
proper waste
disposal.
4.
Public Event Outreach
Provide stormwater educational
1. Staff will have a
1. Annually
1. Number of events
information to the general public
booth at community
held/attended;
at community events,
events to disperse
Permit Years 1-5
Number of attendees;
stormwater outreach
(FY19/20 — FY23/24)
Number of materials
materials through the
handed out.
use of interactive
educational games and
activities.
5.
Student/teacher outreach
Provide educational information
1. Staff will provide in
1. Annually
1. Number of classes
to students and teachers through
class instruction to 7th
provided;
classroom, workshop, and hands-
and/or 8' grade STEM
Permit Years 1-5
Number of students
on activities related to stormwater
students.
(FY19/20 — FY23/24)
present.
BMPs.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 21, 2019
Page 24
Table 13: Public Education and Outreach BMPs
2. Staff will conduct
2. Annually
2. Number of
stormwater related
workshops provided;
workshops with
Permit Years 1-5
Number of teachers
teachers.
(FY19/20 — FY23/24)
attending.
6.
Printed Materials
WPCOG Staff will design new
1. WPCOG Staff will
1. Permit Year 1
1. Number of new
printed materials for target
create printed material
materials created for
audiences to aid stormwater
for local government
(FY19/20)
addressing illicit
education and upon completion
distribution addressing
discharge and
begin distribution.
illicit discharge and
stormwater best
stormwater best
practices.
practices.
2. WPCOG Staff will
2. Annually
2. Number of materials
distribute printed
distributed.
materials at events,
Permit Years 1-5
school presentation,
(FY19/20—FY23/24)
and have them on
display for public
acquisition in
Government buildings.
Digital educational
information/
opportunities.
7.
Annual Water Quality Conference
The Town will sponsor the
1. Provide one
1. Annually
1. Number of
Western Piedmont Council of
presentation about one
attendees;
Governments and Lenoir Rhyne
of the six NPDES
Permit Years 1-5
Stormwater topic/s
University's Annual Water
Minimum Control
(FY19/20 — FY23/24)
presented referencing
Quality Conference to provide
Measures at each
the minimum control
outreach and public participation.
annual conference. A
measures.
WPCOG staff will conduct the
different MCM will be
annual regional conference for
presented on each
continued education to local
year,
government officials, staff,
educators, and the general public.
8.
Evaluate Pollutants Sources and Audiences
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 25
Table 13: Public Education and Outreach BMPs
Evaluate the target pollutants,
1. Evaluate following
1. Annually
1- 2. Evaluate and
sources, and associated target
target pollutants:
document number of
audiences likely to have
litter, sediment, gray
Permit Years 1-5
current and new target
significant stormwater impacts
water, fats, oils,
(FY19/20 — FY23/24)
pollutants, sources,
and why they were selected.
grease, urban farming,
and audiences by
underground storage
identifying them in the
tanks, super fund sites,
annual report and
chemicals, illicit
update the plan (when
discharges, illegal
necessary). This will
dumping and improper
be carried out by
disposal of waste.
WPCOG personnel
2. Evaluate the
2. Annually
through program
following target
documentation and
audiences: residents,
Permit Years 1-5
visualized/tracked with
businesses, schools,
(FY19/20 — FY23/24)
GIS data and mapping
construction activity,
tools.
commercial, farms,
industrial,
development
community, general
public and municipal
employees,
9.
Evaluate Public Education and Outreach BMPs.
Evaluate the successful
1. Administer a
1. Annually
1. Number of
components of outreach through
random survey to
responses received to
interest and feedback.
Town residents,
Permit Years 1-5
determine if current
businesses, schools,
(FY19/20—FY23/24)
efforts are beneficial to
commercial, farms,
the public education
industrial,
and outreach program.
development
community, general
public and municipal
employees.
Permit
2.1.7 and 3.2.3: Web Site
Ref.
Measures to provide a web site designed to convey the program's message and provide online materials
including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory
mechanisms, providing the le al an ority necessary to implement and enforce the re uirements of the permit
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
10.
Website
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 26
Table 13: Public Education and Outreach BMPs
Maintain the already established
1. Maintain and update
1. Annually
1. Number of times
website designed to convey the
stormwater program
website material is
program's message. The Town
information on the
Permit Years 1-5
updated per year; what
webpage will convey the
existing municipal
(FY19/20 — FY23/24)
changes were made.
importance of water quality and a
website.
link to the WPCOG Stormwater
2. WPCOG staff will
2. Annually, beginning
2. Number of times
Partnership will be placed on the
maintain and update
in Permit Year 2
website material is
Town's website. The WPCOG
the regional
updated per year;
Stormwater Partnership webpage
stormwater websites;
Permit Years 2-5
Number of participants
will provide educational resource
by posting the MS4
(FY20/21 — FY23/24)
using the stormwater
links and opportunities for public
Annual Self-
website, measured
participation within the Town.
Assessment, verifying
through opening the
all links and contact
page link.
information are
current/active, posting
the current year fliers
and reset the view
counter.
11.
Education Regarding Illicit Discharges
Provide educational information
1. Train municipal
1. Annually
1. Number of
to municipal employees,
employees in illicit
employees trained;
businesses, citizens and schools
discharge detection
Permit Years 1-5
Number of trainings
of hazards associated with illicit
and elimination.
(FYI 9/20 — FY23/24)
held,
2. Distribute material
2. Annually
2. Amount of material
discharges, illegal dumping, and
improper disposal of waste.
to target audiences
distributed to each
(municipal employees,
Permit Years 1-5
group:
schools, businesses,
(FY19/20 — FY23/24)
Students
and citizens).
Municipal Employees
Business Employees
Citizens.
3. Provide education
3. Continuous, upon
3. Number of
during enforcement
violation investigation,
corrective enforcement
process.
actions; number of
Permit Years 1-5
citizen interactions.
(FY19/20 — FY23/24)
Permit
3.2.5: Stormwater Hotline
Ref.
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Im lementation
Annual Reporting
Metric
12.
Hotline
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 27
Table 13: Public Education and Outreach BWs
Provide a stormwater
1. Establish a hotline
1. Permit Year 1
1. Yes or No; Phone
hotline/helpline for public
number for stormwater
number.
education and outreach.
complaints and
(FY19/20)
information.
2. Identify specific
2. Permit Year 1
2. Yes or No; Staff
staff members who
name and position.
will serve as
(FY19/20)
stormwater education
and hotline contacts.
3. Record number and
3. Annually, after
3. Number of phone
type of complaints,
establishment of
calls received and the
concerns and
stormwater hotline.
context of the call;
information related to
Type of call,
each call.
Permit Years 2-5
information provided
(FY20/21 — FY23/24)
during the call, date of
call, and location of
caller.
4. Train stormwater
4. Annually, beginning
4. Document and
education and hotline
in Permit Year 1
report number of staff
contacts in general
trained, training dates
stormwater awareness,
(FY19/20)
and topics covered.
complaint call
protocols and
appropriate contacts
for referral or typical
stormwater issues.
5. Publicize contact
5. Continuous from
5. Document and
information on the
date of first annual
report a summary of
Town and WPCOG
training (see BW
the number of
Stormwater
12.13.4. above) in
inquiries received, the
Partnership webpages.
Permit Year 1
general type of inquiry
(education, outreach,
(FY19/20)
complaint), and the
contact mechanism
(phone, email, web
page, walk-in).
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 28
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
In reference to M34 Permit Self Audit Report— Public Involvement and Participation, Permit Citation
H.C.2..a. Volunteer Community Involvement Program, H.C.2.b. Mechanism for Public Involvement, and
II.C.2.c. Hotline/Help Line: The Town plans to grow that effort in the future. Proximity to Lake
Rhodhiss provides opportunity for public interest in events. The Town of Rutherford College will
establish a hotline, webpage reporting form and survey/s, along with the use of the existing WPCOG
Water Resource Committee to gather public input. Stream clean-ups will be completed on an annual
basis. All events, programs, and public forums will be announced through social media.
This SWMP identifies the minimum elements and implementafion of a Public Involvement and
Participation Program that complies with applicable State, Tribal and local public notice requirements.
The Town of Rutherford College will manage, implement and report the following public involvement
and participation BMPs.
Table 14: Public Involvement and Participation BMPs
Permit
3.3.1: Public Input
Ref.
Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Im lementation
Metric
13.
Hotline for Public Input
Provide mechanisms for public
1. Establish a Hotline
I. Permit Year 1
1. Number of calls
input on stormwater issues and
for public input.
received/issues
the stormwater program.
Define who is in
(FY 19/20)
reported.
charge of the hotline.
Establish a
"standardized script of
questions" for the
hotline to make data
recording more
consistent.
2. Maintain a hotline
2. Continuous, once
2. Number of updates
for public input.
established in Year 1
to hotlines questions
(script for
Permit Years 2-5
standardization).
(FY20/21 — FY23/24)
14.
Web based form reporting
Provide mechanisms for public
1. Establish a web
1. Permit Year 1
1. Tool established —
input via email format for
based email complaint/
Yes or No, Status.
stormwater issues and the
reporting tool to be
(FY 19/20)
stormwater program.
housed on the regional
website.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 29
Table 14: Public Involvement and Participation BMPs
2. Use the tool to log
2. Continuous,
2. Number of
and respond to
following the
questions asked via the
questions regarding the
establishment of the
tool; Number of
public involvement
tool in Permit Year 1.
responses provided by
program,
staff categorized.
Permit Years 2-5
(FY20/21 — FY23/24)
3. Maintain a web
3. Continuous,
3. Number of updates
based email
following the
completed to the web
complaint/reporting
establishment of
tool and reason for
tool on the regional
Permit Year 1.
change.
website.
Permit Years 1-5
(FY 19/20 — FY23/24)
15.
Social Media Outreach — Event Promotion
Create and use a social media
1. Establish social
1. Permit Years 1
1. Facebook page
page to promote stormwater
presence on Facebook
created — Yes or No,
events, projects, and programs.
to promote public
(FY 19/20)
status.
The outreach tool will provide
involvement and
exposure to a large audience.
participation related to
stormwater programs,
events, and projects.
2. Use social media
2. Continuous, after
2. Number and type of
presences to promote
Facebook page is
events, projects and
stormwater events,
established in Permit
programs promoted.
projects, and programs
Year 1.
to engage public
involvement.
Permit Years 1-5
(FYI 9/20 — FY23/24)
16.
Water Resources Committee
Provide mechanisms for public
1. Hold quarterly water
1. Quarterly meetings
1. Number of attendees
input and participation via
resource meetings,
at each meeting, topics
regional meetings on stormwater
open to the public, for
Permit Years 1-5
discussed.
issues and the stormwater
participation in
(FY19/20 — FY23/24)
program,
discussion related to
water quality issues.
17.
Public Survey and Evaluation
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 30
Table 14: Public Involvement and Participation BMPs
Provide mechanisms for public
1. Create and
1. Annually
1. Number of
input by creating a survey to
administer a survey to
invitations sent,
engage the public and gauge
be housed on the
Permit Years 1-5
surveys collected,
public interest in stormwater
regional stormwater
(FY19/20 — FY23/24)
percentage of response
issues and the stormwater
website once a year,
rate and number of
program
open to feedback for a
responses,
total of 4 weeks,
Completed analysis of
the data collected.
Permit
3.3.2: Volunteer Opportunities
Ref.
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Im lementation
Annual Reporting
Metric
18.
Stream Cleanup
Provide volunteer opportunities
1. Hold stream cleanup
1. Annually
1. Number of
for ongoing citizen participation
efforts by engaging
events/participants;
through stream cleanup activities.
groups to conduct
Permit Years 1-5
Number of trash bags
stream cleanup
(FY19/20 — FY23/24)
filled,
activities in
appropriate areas. The
events will be
promoted by the Town
and WPCOG, toward
civic groups.
2. Provide all materials
2. Annually
2. Number of materials
for stream cleanup
distributed.
activities (i.e. gloves,
Permit Years 1-5
trash bags, and trash
(FY19/20 — FY23/24)
pickers) hosted by
Town and WPCOG.
3. The Town and
3. Annually
3. Number of
WPCOG will market
attendees;
the event (hosted by
Permit Years 1-5
Number of social
WPCOG) to the public
(FY19/20 — FY23/24)
media tags and shares;
to obtain volunteers
Number of materials
for stream cleanup
distributed/mailed
efforts to assist in
public awareness and
involvement with the
event.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 31
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
M34 Inspection Report forthe Town of Rutherford College —Illicit Discharge Detection and Elimination
(IDDE), Permit Citation II.D.2.a. IDDE Program: The Town is regulated by the water supply watershed
protection ordinance, which does not contain any specific language on the application of notice of
violations. Written procedures for implementing an IDDE Program have not been completed. In response
the Town will locate priority areas likely to have Illicit discharges, conduct routine dry weather outfall
inspections, identify illicit discharges and trace sources, eliminate the source(s) of an Illicit discharge, and
evaluate and assess the IDDE Program.
The Town will also, in responses to, MS4 Inspection Report for the Town of Rutherford College —Illicit
Discharge Detection and Elimination (IDDE), Permit Citation II.D.2.b. Legal Authority, the Town will
create, adopt, maintain and enforce a stormwater ordinance and other regulatory mechanisms that provide
the legal authority to prohibit illicit connections and discharges to the MS4.
The Town maintained a map, but the major outfalls were not identified at time of audit. Since the audit
was complete, the Town hired West Consulting to map all outfalls, inlets, basins, and flow direction
(II.D.2.c. Storm Sewer System Map). In the future the Town will continue to update the MS4 map as new
development occurs (Permit Ref: 3.4.1 BMP 19).
In the last permit cycle, the Town did not conduct dry weather screening or maintain written procedures
for dry weather field activity (II.D.2.d. Dry Weather Flow Program). Within the Stormwater
Management Plan a schedule is to be created to conduct dry weather screening each winter. Data such as
date screening occurred, location of inspected outfall, and photos of outfall will be recorded in GIS.
The Town of Rutherford College Stormwater Management Plan outlines the response authority, but not
procedures (II.D.2.e.). Due to water supply watershed not identifying notice of violation procedures, the
Town of Rutherford College issued no NOVs. Currently, there is not a way to track and document
investigations (II.D.21 & j.).Within the new permit cycle, as stated below, the Town will be adopting an
IIDE Plan to establish written procedures. A chart will be used to track and document IDDE cases. This
will allow the Town to identify priority areas based on historical data.
Further, the Town will train municipal staff and the general public to identify illicit discharge and illegal
dumping through the use of educational outreach materials and training opportunities. Previously, no
training had been administered to employees (II.D.2.g.). Information to the public was provided in bill
inserts on a regular basis (II.D.21.). Educational material will be available to help educate public
employees, businesses, and the general public about hazards associated with illicit discharges and the
improper disposal of waste.
Public complaints of any kind can be report through a webpage portal; however the line of
communication was not publicized (II.D.2.i). The Stormwater hotline phone number, as mentioned in the
public education and outreach and illicit discharge areas of this plan.
The Town of Rutherford College will develop, manage, implement, document, report and enforce an
Illicit Discharge Detection and Elimination Program which shall, at a minimum, include the following
illicit discharge detection and elimination BMPs.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 32
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
3.4.1: MS4 Map
Ref.
Measures to develop, update and maintain a municipal storm sewer system map including stormwater
conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
19.
MS4 Map
Update and maintain a municipal
1. Verify accuracy of
1. Permit Year 1
1. Number of
storm sewer system map
existing GIS map/data
(FY 19/20)
corrections needed.
including stormwater
by comparing current
conveyances, flow direction,
data to field located
major outfalls and waters of the
major outfalls.
United States receiving
2. Locate funding
2. Permit Years 2
2. Funding source was
stormwater discharges.
source for future
(FY 20/21)
located: Yes or No;
mapping needs (such
Status.
as, but not limited to
grants, fees, and
fundraisers).
3. Update existing map
3. Semi-annually
3. Number of updates;
if discrepancies are
completed.
determined in BMP
Permit Years 3-5
19.B.1. This data will
(FY21/22 - FY23/24)
be collected with a
mixture of preexisting
GIS data (following its
validation), as well as,
field work based by
town employees based
off of known existing
information and
records.
4. Add new
4. Annually
4. Number of new
infrastructure to map
miles of pipe, type of
as new construction
Permit Years 1-5
pipe, number of
occurs, to include Pipe
(FY19/20 — FY23/24)
SCMs, number of
locations, flow
outfalls, flow direction
direction, inverts,
located, number of
ditches, inlets, catch
conveyances mapped,
basins, manholes,
were receiving bodies
outfall size location
located/marked.
and conditions.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 33
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
3.4.2: Regulatory Mechanism
Ref.
Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to
prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS49
including enforcement procedures and actions.
A I
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
20.
Ordinance Adoption
Municipality will adopt and apply
1. Draft and adopt a
1. Permit Year 1
1. Yes or No/status
the IDDE ordinance that provides
local Illicit Discharge
summary;
legal authority to prohibit, detect,
and Elimination
(FY19120)
Date ordinance
and eliminate illicit connections
ordinance.
adopted.
2. Train staff (field and
2. Permit Year 1
2. Number of staff
and discharges, illegal dumping
and spills into the MS4 -
office) in illicit
trained; record of
including enforcement procedures
discharge detection
(FY19/20)
staff's name, date,
and actions.
and elimination
position and
procedures and
responsibilities.
enforcement actions.
3. Enforcement of the
3. Continuous,
3. Number of
IDDE ordinance to
following the adopted
incidences reported;
prohibit, detect, and
of the IDDE
Number of incidences
eliminate illicit
Ordinance.
resolved, Number still
connections and
in progress of
discharges, illegal
Permit Years 1-5
abatement at time of
dumping and spills in
(FY19/20 — FY23/24)
annual report.
to the MS4.
Permit
3.4.3: IDDE Plan
Ref.
Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal
dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4.
The plan shall provide standard procedures and documentation to:
a) Locate priority areas likely to have illicit discharges,
b) Conduct routine dry weather outfall inspections,
c) Identify illicit discharges and trace sources,
d) Eliminate the source(s) of an illicit discharge, and
e) Evaluate and assess the IDDE Program.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Im lementation
Metric
21.
IDDE Plan
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 34
Table 15: Illicit Discharge Detection and Elimination BMPs
Establish a written IDDE Plan to
1. Develop written
1. Permit Year 1
1. Yes or No/status
detect and address illicit
IDDE Plan to define
summary; date draft
discharges, illegal dumping and
the process of
(FY19/20)
plan is developed.
any non-stormwater discharges
mapping, identifying
identified as significant
tracking, and
Submit IDDE Plan to
contributors of pollutants to the
processing: illicit
DEQ for approval.
MS4.
discharges, Illegal
dumping violations,
and significant
contributors of
pollutants to the MS4.
the MS4 (permit
reference 3.4.1 MS4
Map),
2. Train staff on the
2. Permit Year 1
2. Number of
processes defined in
employees trained,
the IDDE Plan
(FY19/20)
date of training and
(reference 21.B.1.)
position of employee.
3. Adopt the IDDE
3. Permit Year 1
3. Yes or No/status
Plan
summary;
(FY19/20)
Date procedures
adopted.
4. Implement/Enforce
4. Continuous
4. Number of IDDE
the adopted IDDE
complaints resolved.
Plan.
Permit Years 2-5
(FY20/21 — FY23/24)
5. Maintain and assess
5. Permit Year 5
5. Yes or No; date plan
the IDDE Plan based
reviewed and findings;
on reporting metrics
(FY23/24)
Number of changes
from previous year's
needed.
findings.
22.
Location of Priority Areas
Establish and maintain procedures
1. Use MS4 map to
1. As BMP 19 is being
1. Number and
to locate priority areas likely to
locate outfalls in
completed, priority
location of each
have illicit discharges.
conjunction with high
areas will be
priority area
pollution risk areas
established.
determined.
(based on tax office
data outlining land
Continuous,
classification). To
Permit Years 1-5
establish high priority
(FY19/20 — FY23/24)
areas.
23.
Dry Weather Outfall
Inspections
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 35
Table 15: Illicit Discharge Detection and Elimination BMPs
Establish procedure to conduct
1. Create a schedule
1. Yearly (winter),
1. Date inspections
routine dry weather outfall
and record inspection
occurred, location of
inspections
data in GIS for dry
Permit Years 1-5
inspected outfall, and
weather outfall
(FYI 9/20 — FY23/24)
photos of outfall.
inspections such as
photos and location.
24.
Illicit Discharges and Trace Sources
Establish procedures to track and
1. Establish procedures
1. Permit Year 1
1. Was the tracking
document investigations.
to identify illicit
document established
discharges and trace
(FY19/20)
Yes or No; Status.
sources.
2. Maintain tracking
2. Continuous,
2. The date(s) the
documentation that
following
illicit discharges were
follows the procedures
establishment in Year
observed, the results of
listed in Permit
1.
the investigation,
reference 3.4.3 BMP
follow-up
24.B.1.
Permit Years 1-5
documentation, and
(FY19/20 — FY23/24)
the date the
investigation was
closed.
25.
Maintain and Implement IDDE
Plan
Maintain and implement the
1. Assess the local
1. Continuous, after
1. Provide status
IDDE Plan to detect and address
priority areas likely to
plan is established in
summary; number of
illicit discharges, illegal dumping,
have illicit discharges.
Permit Year 1,
priority areas (location
and any non-stormwater
and/or use)
discharges identified as
Permit Years 1-5
determined.
significant contributors of
(FY19/20 — FY23/24)
2. Conduct routine dry
2. Continuous, after
2. Number of outfalls
pollutants to the MS4.
weather outfall
plan is established in
inspected.
inspections — with the
Permit Year 1.
goal of inspecting all
outfalls over the 5 year
Permit Years 1-5
permit period.
(FY19/20 — FY23/24)
3. Identify illicit
3. Continuous, after
3. Number of illicit
discharges and trace
plan is established in
discharges and non -
sources.
Permit Year 1.
illicit discharges
identified.
Permit Years 1-5
(FY19/20 — FY23/24)
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 36
Table 15: Illicit Discharge Detection and Elimination BMPs
4. Eliminate the
4. Continuous, after
4. Number of
sources of illicit
plan is established in
corrective actions
discharge.
Permit Year 1.
completed.
Permit Years 1-5
(FYI 9/20 — FY23/24)
5. Evaluate and assess
5. Annually
5. Number of
the IDDE program —
recommended
Identify where
Permit Years 1-5
improvement to
improvement can be
(FY19/20 — FY23/24)
achieve best
made based on
management practices.
statistical data
collected.
Changes must be
approved by DEQ
from the previously
approved IDDE Plan.
Permit
3.4.4: IDDE Tracking
Ref.
Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was
observed, the results of the investigation, any follow-up of the investigation, the date the investigation was
closed, the issuance of enforcement actions, and the ability to identify chronic violators.
BMP
A
B
I C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Im lementation
Annual Reporting
Metric
26.
IDDE Tracking
1. Establish a GIS
1. Permit Year 1
1. Yes or No, status
database application
summary;
for tracking illicit
(FY 19120)
Date application
discharge connections
created.
and illegal dumping,
outlining who made
the complaint, location
of complaint, note
prior offenses, status
and action taken.
DRAFT NCS000480 SVJMP
Town of Rutherford College
September 27, 2019
Page 37
Table 15: Illicit Discharge Detection and Elimination BMPs
Staff will create a mechanism for
2. Track illicit
2. Continuous,
2. Number of issues
tracking and documenting the
discharges/connections
following
reported by staff;
date(s) an illicit discharge, illicit
and illegal dumping
establishment in
Number of issues
connection or illegal dumping
with the GIS tool
Permit Year 1,
reported by citizens;
was observed/investigated, the
(Permit reference 3.4.4
Summary of findings.
results of the investigation, any
BMP 18.13.1 ),
Permit Years 1-5
follow-up of the investigation,
Including the ability to
(FYI 9/20 — FY23/24)
the date the investigation was
differentiate staff
closed, the issuance of
discovery from citizen
enforcement actions, and the
reporting to allow for
ability to provide the ability to
review of outreach
identify/record chronic violators.
program.
3. Upon investigation,
3. Continuous,
3. Number of
correct Illicit
following
corrective actions
Discharge/connection
establishment in
taken, documentation
and Illegal Dumping.
Permit Year 1.
of violations.
Permit Years 1-5
(FY19/20 — FY23/24)
4. Establish and
4. Continuous,
4. Number of chronic
maintain a list of
following
violators identified,
chronic violators, as
establishment in
applicable
Permit Year 1,
Permit Years 1-5
FY19/20 — FY23/24)
5. Evaluate and assess
5. Continuous,
5. Number of
the IDDE tracking
following
recommended
application and
establishment in Year
improvements to
program — Identify
1.
achieve best
where improvement
management practices.
can be made based on
Permit Years 2-5
statistical data
(FY20/21— FY23/24)
collected, problems
encountered and
needs.
Permit
3.4.5: Staff IDDE Training
Ref.
Measures to provide training for municipal staff and contractors who, as part of their normal job
responsibilities, may come into contact with or otherwise observe an illicit discharge, illicit connection or
illegal dumping. Training shall include identifying and reporting illicit discharges, illicit connections and
illegal dumping. Each staff training event shall be documented, including the agenda/materials, date, and
number of staff participating.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
DRAFT NC5000480 SWMP
Town of Rutherford College.
September 27, 2019
Page 38
Table 15: Illicit Discharge Detection and Elimination BMPs
27.
Staff Training
Train municipal staff and
1. Identify municipal
1. Annually
1. Number of
contractors to identify and report
staff members or
employees (contractors
illicit discharges, illicit
contractors that are
Permit Years 1-5
included) identified.
connections, illegal dumping and
likely to observe an
(FYI 9/20 — FY23/24)
spills.
Illicit discharge, illicit
connection and illegal
dumping.
2. Hold IDDE training
2. Annually
2. Number of
events to educate staff
events/personnel
and contractors in
Permit Years 1-5
trained; provide
identifying and
(FYI 9/20 — FY23/24)
specific
reporting: illicit
agenda/materials, date
discharges, illicit
and staff.
connections, illegal
dumping, ands ills.
28.
IDDE Educator
Establish appropriate staff
1. Identify specific
1. Permit Year 1
1. Document specific
contacts to field inquiries
staff
staff positions.
regarding IDDE education,
members/positions
(FY19/20)
outreach and complaints,
who will serve as
IDDE education and
hotline contacts.
2. Train IDDE
2. Annually, beginning
2. Document and
education and hotline
Permit Year 1
report number of staff
contacts in IDDE
(position) trained,
awareness, complaint
Permit Years 1-5
training dates, and
call protocols, and
(FYI 9/20 — FY23/24)
topic covered.
appropriate contacts
for referral.
3. Publicize contact
3. Continuous, from
3. Document and
information about
date of first annual
report a summary of
IDDE reporting
training (see BMP
the number of
through social media
28.B.2) in Permit Year
inquiries received, the
and on the Towns
1
general type of inquiry
webpage..
(educational outreach
(FY19/20)
or complaint), and the
contact mechanism
(phone, email,
web a e, walk-in).
3.4.6: IDDE Reporting
nReL
Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be
publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained
personnel.
DRAFT NCS000480 5WMP
Town of Rutherford College
September 27, 2019
Page 39
Table 15: Illicit Discharge Detection and Elimination BMPs
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
29.
IDDE Reporting Hotline
Provide a hotline for the public
1. Create a hotline for
1. Permit Year 1
1. Yes or No, status
and staff to report illicit
reporting IDDE
summary; date
discharges, illegal dumping and
concerns. Designate
(FY19/20)
application created; list
spills,
which staff are in
of staff charged with
charge of resolving the
resolving the reported
issue reported via the
issues.
hotline. Develop a set
of standard scripts for
consistent record
keeping.
2. Train hotline staff to
2. Continuous, after
2. Were staff trained —
differentiate between
hotline is established.
Yes or No, status;
illicit discharge
Names of trained staff
complaints and
Permit Years 1-5
in list format.
stormwater
(FY19/20 — FY23/24)
complaints. The staff
will also be trained to
keep adequate records
of the calls for metrics.
3. Maintain the hotline
3. Semi-annually
3. Number of phone
as a mechanism for
calls received,
reporting by updating
Permit Years 1-5
the standard script
(FY19/20 — FY23/24)
based off of problems
recognized by hotline
employees.
4. Publicize Hotline by
4. Continuous,
4. Amount of materials
including the number
following the
distributed; Number of
mall educational
establishment of the
shares like, comments,
materials distributed.
hotline.
reviews and responses
Share the hotlines
on relevant social
number on the Town
Permit Years 1-5
media.
website and social
(FYI 9/20—FY23/24)
media accounts.
30.
IDDE Reporting Web -based Reporting Form
Staff will establish and maintain a
1. Create a form for
1. Permit Year 1
1. Yes or No, status
web -based google form where
web based report.
summary;
complaints can be entered and
(FY19-20)
Date form is created.
sent to the appropriate reporting
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 40
Table 15: Illicit Discharge Detection and Elimination BMPs
individual. Publicize reporting
2. Establish links to
2. Permit Year 1
2. Yes or No, status
tool in education outreach
reporting form tool on
summary;
materials.
the Town website and
(FY19-20)
Date links are created.
social media (included,
but not limited to,
Facebook).
3. Maintain the web
3. Annually, following
3. Number of reports
based reporting tool.
the creation of BMP
made; method of
30.13.1. & 2,
publicizing reporting
option.
Permit Years 1-5
(FY 19/20 — FY23/24)
3. Publicize web -based
3. Continuous
3. Amount of materials
reporting tool by
following
distributed.
including the
establishment of the
address/location in all
web tool.
educational materials
distributed.
Permit Years 1-5
(FY19/20 — FY23/24)
Me
IDDE Reporting Efficiency
Staff will provide a rapid response
1. Establish GIS
1. Permit Year 1
1. Yes or No, status
to all complaints received. Staff
application to track
summary;
will record the response dates and
time of complaint, site
(FY19/20)
Date application
summary of results to improve
visit, type of complaint
created.
IDDE program and application,
and all
enforcement/resolution
measures.
2. Evaluate response
2. Annually, following
2. High/Low times
time. Work to
establishment of GIS
elapsed, and overall
minimize response
application.
average time between
time to reported issues
the report and staff
and record what is
Permit Years 1-5
investigation; goal is
causing those issues to
(FY19/20 — FY23/24)
to improve time to
be fixed in later
achieve best
iterations of the plan.
management practices,
DRAFT NCS000480 SWMP
Town of Rutherford College
September 21, 2019
Page 41
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H I the Town of Rutherford College relies upon the or
Carolina Sedimentation Pollution Control Act (SPCA) of 1973 and the NCGO10000 permit for
construction activities as qualifying alternative programs to meet the NPDES MS4 Permit requirements
for all construction site runoff control measures to reduce pollutants in stormwater runoff from
construction activities that result in land disturbance of greater than or equal to one acre and any
construction activity that is part of a larger common plan of development that would disturb one acre or
more.
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Meets Whole
Permit
State or Local Program Name
Legal
Implementing Entity
or Part of
Reference
Authority
Requirement
3.5.1 -
State Implemented SPCA Program
15A NCAC
NCDEQ
Whole
3.5A
Chapter 04
The Town of Rutherford
College
also implements
the following BMPs to meet NPDES MS4 Permit
requirements.
Table 17: Construction Site Runoff Control BMPs
Permit
3.5.6: Public Input
Ref.
Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
32.
Municipal Staff Training
Train municipal staff who receive
1. Establish a sheet/list
1. Permit Year 1
1. Number and names
calls from the public on the
of trained municipal
of staff trained;
protocols for referral and tracking
staff and citizens who
(FY19/20)
number of responses
of construction site runoff control
have reported
generated by staff.
complaints.
construction run-off
issues.
2. Train municipal
2. Annually, following
2. Document and
staff on proper
establishment of BMP
report number of staff
handling of
32.13.1.
trained, training
construction site runoff
date(s) and topics
control complaints.
Permit Years 1-5
covered.
(FY19/20 — FY23/24)
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 42
Table 17: Construction Site Runoff Control BMPs
33.
Means of Public Input
1. Develop a survey to
1. Permit Year 1
1. Was the survey
Develop surveys and programs to
obtain feedback about
developed: Yes or No,
give citizens methods of
public perspective
(FY19/20)
Status.
responding to how construction
about construction
runoff is being managed. Ask
runoff in the Town.
2. Administer the
2. Annually, following
2. Number of surveys
questions regarding: how they
view construction runoff in the
survey to be
the development of the
administered; number
Town, what they think should be
distributed through
survey.
of valid surveys
changed to improve upon said
Town utility bills and
received.
problems, and where they believe
left in municipal
Years 2-5
there should be better focus.
buildings.
(FY 20/21 - FY 23/24)
3. Develop a web-
3. Permit Year 1
3. Web -based tool
based reporting form
developed; Yes or No,
that allows citizens
(FY19/20)
Status.
and the development
community (separately
distinguished) to write
concerns and report
construction runoff
issues. The tool will
be accessible on the
Town website and
social media.
4. Administer the web-
4. Continuous,
4. Number of reports
based reporting form
following the
from Citizens; Number
in BMP 33.13.3.
development of the
of reports from
web -based tool in
development
Permit Year 1.
community.
Permit Years 2-5
(FY 20/21 - FY 23/24)
5. Publicize the ability
5. Continuous,
5. Number of clicks on
to report concerns
following development
the Town website;
about construction
in Permit Year 1.
number of likes and
runoff issues via forms
shares on Towns social
(BMP 33.B.3) on the
Permit Years 2-5
media platforms.
Town website and
(FY 20/21 - FY 23/24)
social media.
Permit
Ref.
3.5.5: Waste Management
Measures to require construction site operators to control waste such as discarded building materials, concrete
track washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to
water quality.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Im lementation
Annual Reporting
Metric
DRAFT NCS000480 SWMP
Town of Rutherford College
September 2I, 2019
Page 43
Table 17: Construction Site Runoff Control BMPs
34.
Waste Management
Require construction site
1. Develop an
1. Permit Year 1
1. Ordinance
operators to control waste at the
ordinance that
developed: Yes or No,
construction site that may cause
addresses construction
(FY19/20)
Status.
adverse impact to water quality.
site waste.
2. Adopt the ordinance
2. Permit Year 1,
2. Ordinance adopted:
established in BMP
following development
Yes or No, Status.
34.13.1.
of ordinance
(FY19/20)
3. Enforce the adopted
3. Continuously,
3. Number of permits
ordinance using a GIS
following adoption of
issued with erosion
application (Permit
the ordinance.
and sedimentation
Reference 3.4.4, BMP
control plans;
26.13.1) to track and
Permit Years 1-5
Number of corrective
document
(FY19/20 — FY23/24)
actions
construction site
taken/violations issued
waste concerns and
to active construction
corrective actions
sites identifying waste
taken.
management
violations.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 44
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
MS4 Inspection Report for the Town of Rutherford College — Post -construction Site Runoff Control
Program Implementation Status, Permit Citation: Currently, the Town does not have a mechanism in
place to require deed restrictions and protective covenants. Within the ordinance established in Permit
Year One enabling language granting the Town of Rutherford College the ability to require deed
restrictions and protective covenants (II.F.2.e.) will be included.
An inventory of projects willbe kept and proactive inspections will be adm nistered by Staff semi-
annually. A private engineer will certify each SCM annually to ensure functionality (II1.2.g.) Upon
non-compliance, enforcement action will be taken, not a common practice in years past, but now the
Town will have a spreadsheet to record enforcement action to obtain compliance (II.F.2d.).
MS4 Inspection Report for the Town of Rutherford College — Post -construction Site Runoff Control
Program Implementation Status, Permit Citation: II.F.3.c. Nutrient Sensitive Waters: The Town had not
designed or constructed any SCMs in the permitted area specifically to reduce nutrient loads.
This SWMP identifies the minimum elements to develop, implement and enforce a program to address
stormwater runoff from new development and redevelopment projects that disturb greater than or equal to
one acre, including projects less than one acre that are part of a larger common plan of development or
sale, that are located within the Town of Rutherford College and discharge into the MS4. These elements
are designed to minimize water quality impacts by utilizing a combination of structural Stormwater
Control Measures (SCMs) and/or non-structural BMPs appropriate for the community, and ensure
adequate long-term operation and maintenance of SCMs.
In accordance with 15A NCAC 02H .0153 and .1017, the Town of Rutherford College implements the
following State post -construction program requirements, which satisfy the NPDES Phase II M34 post -
construction site runoff control requirements as Qualifying Alternative Program(s) (QAPs) in the MS4
area(s) where they are implemented.
Table 18: Qualifying Alternative Programs) for Post -Construction Site Runoff Control Program
Local Ordinance /Regulatory
State OAP Name
State Requirements
Mechanism Reference
Water Supply Watershed (WS-IV)
15A NCAC 2B
WS-IV Watershed Ordinance (See
.0620 - .0624
map)
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 45
DRAFT NC5000480 SWMP
Town of Rutherford College
September 27, 2019
Page 46
The Town of Rutherford College has existing requirements including the presence of a Qualifying
Alternative Program(s) in all of the Town limits. The Qualified Alternative Program is the Lake
Rhodhiss water supply watershed Critical Area WS-IV and Protected Area WS-lV. To ensure
compliance with the NPDES MS4 Phase B post -construction program requirements the Town of
Rutherford College applies the post -construction standards throughout the Town Limits, including the
area that is located within the water supply watershed. These requirements are to be adopted as local
ordinance(s) per BMP 37.13.1. and implementation per BMP 37.13.3-4, and are summarized in Table 19
below.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 47
Table 19: Summary of Existing Post -Construction Program Elements
Permit Requirements for
Plan Review and Approval
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date
Adopted
3.6.2(a)
Authority
Stormwater
Ordinance
Section
102
N/A
3.6.3(a) & 15A NCAC 0211.0153(c)
Federal, State & Local Projects
Stormwater
Ordinance
Section
105
N/A
3.6.3(b)
Plan Review
Stormwater
Ordinance
Section
202
N/A
3.6.3(c)
O&M Agreement
Stormwater
Ordinance
Section
402
N/A
3.6.3(d)
O&M Plan
Stormwater
Ordinance
Section
402
N/A
3.6.3(e) Deed
Restrictions/Covenants
Stormwater
Ordinance
Section
302 and 303
N/A
3.6.3(f)
Access Easements
Stormwater
Ordinance
Section
408
N/A
Permit Requirements for
Inspections and Enforcement
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date
Adopted
3.6.2(b)
Documentation
Stormwater
Ordinance
Section
401
N/A
3.6.2(c)
Right of Entry
Stormwater
Ordinance
Section
402
N/A
3.6.4(a)
Pre -CO Inspections
Stormwater
Ordinance
Section
203
N/A
3.6.4(b)
Compliance with Plans
Stormwater
Ordinance
Section
203
N/A
3.6.4(c)
Annual SCM Inspections
Stormwater
Ordinance
Section
401
N/A
3.6.4(d)
Low Density Inspections
Stormwater
Ordinance
Section
302
N/A
3.6.4(e)
Qualified Professional
Stormwater
Ordinance
Section
401
N/A
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date
Adopted
3,6.6(a)
Pet Waste
Stormwater
Ordinance
307
N/A
3.6.6(b) On -Site Domestic
Wastewater Treatment
Stormwater
Ordinance
Section
308
N/A
The annual reporting metrics for the post construction program are provided in Table 20: Post
Construction Site Runoff Control BMPs below.
Table 20: Post Constriction Site Runoff Control BMPs
Permit
4.1.3: Minimum Post -Construction Reporting Requirements
Ref.
Measures to document activities over the course of the fiscal year (July 1 — June 30) including appropriate
information to accurately describe ro ress, status, and results.
A
1 11
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Im lementation
Metric
35.
Standard Reporting
Implement standardized tracking,
1. Track number of
1. Continuous
1. Number of plan
documentation, inspections and
low density and high
reviews performed for
reporting mechanisms to compile
density plan reviews
Permit Years 1-5
low density and high
appropriate data for the annual
performed.
(FY19/20 — FY23/24)
density.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 48
Table 20: Post Construction Site Runoff Control BMPs
self -assessment process. Data
2. Track number of
2. Continuous
2. Number of plan
shall be provided for each Post-
low density and high
approvals issued for
Construction/ Qualifying
density plans
Permit Years 1-5
low density and high
Alternative Program being
approved.
(FY19/20 — FY23/24)
density.
3. Maintain a current
3. Continuous
3. Summary of number
implemented as listed in Tables
18 and 19.
inventory of low
and type of SCMs
density projects and
Permit Years 1-5
added to the inventory;
constructed SCMs
(FY19/20 — FY23/24)
and number and
including SCM type or
acreage of low density
low density acreage,
projects constructed;
location and last
Total number of SCMs
inspection date.
at time of review.
4. Track number of
4. Continuous
4. Number of SCM
SCM inspections
inspections performed.
performed.
Permit Years 1-5
(FY19/20 — FY23/24)
5. Track number of
5. Continuous
5. Number of low
low density
density inspections
inspections performed
Permit Years 1-5
performed.
- with the goal of
inspecting all low
(FY19/20 — FY23/24)
density projects over
the 5 year permit
period.
6. Track number and
6. Continuous
6. Summary of number
type of enforcement
and type of
actions taken.
Permit Years 1-5
enforcement actions
(FY19/20 — FY23/24)
taken.
Permit
2.3 and 3.6: Qualifying Alternative Program(s)
Ref.
Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state program
requirements.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
36.
Qualifying Alternative Program
The QAP requirements are applicable to a portion of the Town of Rutherford College; however the Phase 11
Post -construction Stormwater Ordinance is being administered to fulfill both requirements.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 49
Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.2: Legal Authority
Ref.
Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review
designs and proposals for new development and redevelopment to determine whether adequate stormwater
control measures will be installed, implemented, and maintained, (b) request information such as stormwater
plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance
with the Post -Construction Stormwater Management Program, and (c) enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater
discharges to determine whether there is compliance with the Post -Construction Stormwater Management
Program.
MP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
37.
Phase II Post -construction Stormwater Ordinance
This permit requirement will be
1. Develop the Phase
1. Permit Year 1
1. Phase II Post -
met once the Phase H Post-
II Post -construction
construction
Construction Stormwater
Stormwater
(FY19/20)
Stormwater Ordinance
Ordinance is adopted, see
Ordinance.
is adopted; Yes or No,
references provided in Table 19.
Status,
2. Adopt the Phase II
2. Permit Year 1
2. Phase II Post -
The Town will adopt and
maintain in effect the Phase II
Post -construction
construction
Stormwater Ordinance, which
Stormwater
(FY19/20)
Stormwater Ordinance
will give the Town legal authority
Ordinance.
adopted: Yes or No,
to review designs for new
status summary;
development and redevelopment,
Date ordinance
to ensure adequate stormwater
adopted,
controls, to request information,
3. Train staff (field
3. Permit Year 1
3. Number of staff
to perform inspections on private
property, and to perform other
and office) in
Stormwater Ordinance
(FY19/20)
trained..
compliance activities related to
procedures and
this measure.
enforcement actions.
The ordinance shall reference the
4. Enforcement of the
4. Continuous,
4. Number of notices
DEQ BMP Design Manual as the
Phase II Post-
following the adoption
of violations issued;
source of standards to be used in
construction
and training of staff
Number of Civil
selecting, designing, evaluating,
Stormwater Ordinance
Citations issued;
and maintaining structural and
to ensure compliance.
Permit Years 2-5
Number still in
non-structural BMPs.
progress of abatement
(FY20/21 - FY23/24)
at time of annual
report,
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 50
Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.3: Plan Review and Approval
Ref.
Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal,
State, and local government projects to comply with Post -Construction Program requirements throughout the
entire MS4 permitted area, unless the entity is subject to its own NPDES MS4 permit or a qualifying alternative
program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than
or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of
development or sale for compliance with 15A NCAC 02H. 1017 and the qualifying alternative programs that
apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that
complies with 15A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan
that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and
protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure
that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A
NCAC 02H 1050 (9) and (10).
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
38.
Plan Review and Approval
This permit requirement will be
1. Establish a post
1. To be completed in
1. Plan review
achieved once the post-
construction plan
Permit Year 1.
checklist was
construction ordinance is adopted
review checklist to
established: Yes or
(Permit Reference 3.6.2 BMP
include all items
(FY19/20)
No, Status.
37.13:2)
needing to be
completed prior to
Review plans for all new
Certificate of
development and redevelopment
Occupancies.
2. Review plans for all
2. Continuous,
2, Number of projects
sites that will disturb greater than
or equal to one acre (including
new development and
following the adopted
reviewed; Number of
projects less than one acre that are
redevelopment sites
of the Post-
projects approved.
part of a larger common plan of
that will disturb greater
construction
development or sale).
than or equal to one
stoimwater ordinance,
(To be documented by
acre. This is to
referenced in BMP
listing type - Non -
including projects less
37.13.2.
governmental,
than one acre that are
Federal, State or Local
part of a larger
Permit Years 1-5
Government)
common plan of
(FYI 9/20 — FY23/24)
development or sale.
This requirement also
applies to Federal,
State, and Local
Government projects.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 51
Table 20: Post Construction Site Runoff Control BMPs
39.
40.
annually to
determine if
establishment of the
made and summary of
items need
to be added
checklist referenced in
reason needed.
or modified.
Operation and Maintenance Agreement and Plan
The Operation and Maintenance
(O&M) agreement require owners
of structural BMPs to perpetually
maintain and operate BMPs
according to the O&M plan
submitted during the plan review
process, and require submission
of an annual inspection report
written by a qualified
professional.
Recordation
1. Ensure that each
project has an approved
O & M Agreement
prior to CO. To be
included in the project
2. Ensure that each
project has an O & M
Plan to require annual
inspections to be
completed by a
qualified professional.
The plan review process shall 1. Ensure each project
include verification that has a recorded deed
permanent legal mechanisms are restrictions and
in effect that ensure development protective covenants in
activities will maintain the project effect to ensure
consistent with approved plans. A development activities
recorded deed or protective will maintain consistent
covenants, along with an accesses with the approved plans
easement is established through (low and high density
recordation. projects).
maintenance access are
recorded in a
permanent easement to
allow access for
inspection and
maintenance of the
SCM.
SCM and associated
2. Ensure that each
BMP 38,B.1.
Permit Years 1-5
fFY19/2n - FY?'
1. Continuous
PermitYeazs 1-5
(FY19/20 — FY23/24)
2. Continuous, to be
included in the project
checklist and required
prior to CO.
Permit Years 1-5
fFY19/2n - FY2'
1. Number of
approved O & M
Agreements.
2.NumberofO&M
inspections
receive
and approved.
1. Continuously, to be 1. Number of deed
included in Lite project restrictions and
checklist and required protective covenants
prior to CO. recorded. Document
high density versus
low density projects.
included Continuously, to be
in the project
checklist and required
prior to CO.
2.
2. Number of access
easements recorded.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 52
Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.4: Inspections and Enforcement
Ref.
Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post -
construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy.
Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s),
(b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual
inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance
Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require
that inspections be conducted by a qualified professional.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Im lementation
Metric
41.
Inspection and Enforcement
This permit requirement will be
1. Prior to issuance of a
1. Continuous
1. Number of Pre -CO
achieved upon the adoption of the
CO a qualified
inspections completed;
Stormwater Post -construction
professional shall
Permit Years 1-5
Number of duplicate
Ordinance, reference Table 19.
perform an inspection
(FYI 9/20 — FY23/24)
inspections required.
After project completion, but
on all project SCMs to
prior to issuance of a certificate of
ensure compliance
occupancy an inspection will be
unless corrections are
completed by a qualified
needed. If corrections
professional to ensure the project
are required, then
has been constructed according to
follow up inspections
plan. Following approval annual
will be required until
inspections by a qualified
the SCM and project
professional will be completed,
sire is complaint prior
Low density projects will be
to the issuance of CO.
2. Municipal staff will
2. Semi -Annual
2. Number of
inspected once in a permit term.
perform inspections of
inspections completed.
all SCMs (both
Permit Years 1-5
Findings reported in
government and non-
(FY19/20 — FY23/24)
chart form.
government).
3. Owner shall have a
3. Annually
3. Number of
certified professional
inspections completed
engineer perform SCM
Permit Years 1-5
and documentation
inspections in
(FYI 9/20 — FY23/24)
received. Number of
accordance with the O
5CM/s not compliant.
& M Agreement and
Document required
DEQ SCM manuals.
corrective action.
DRAFT NCS000480 5WMP
Town of Rutherford College
September 2 t, 2019
Page 53
Table 20: Post Construction Site Runoff Control BMPS
4. 20% or more of the
4. Continuously
4. Number of low
inventoried low density
density projects;
sites will be inspected
Permit Years 1-5
Number of inspection
each year to ensure
(FYI 9/20 — FY23/24)
completed and
impervious has not
findings.
been added producing a
high density situation
creating the need for an
SCM.
Permit
3.6.5: Documentation
Ref.
Measures to maintain adequate documentation and standardized inspection and tracking mechanisms to: (a)
Maintain an inventory of post -construction SCMs and low density projects, (b) Document, track and maintain
records of inspections and enforcement actions. Tracking shall include the ability to identify chronic violators,
and (c) Make available to developers all relevant ordinances, post -construction requirements, design standards,
checklists, and/or other materials.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goals)
Schedule for
Im lementation
Annual Reporting
Metric
42.
Documentation — Low Density
This permit requirement will be
1. Establish a low
1. Once during the
1. List of low -density
achieved upon the adopted of the
density project list
permit cycle.
permitted projects:
Stormwater Post -construction
(including existing
Status to include
Ordinance, reference Table 19.
sites). Upon the
Permit Years 1-5
location, impervious
Ensure tracking and records are
issuing a zoning
(FY19/20 — FY23/24)
calculations,
maintained on low density
permit record the
enforcement action,
projects to ensure that upon
project demographics
chronic violators, date
inspection impervious overages
on the low density list
of last inspection and
can be determined and corrective
for future reference.
findings. Apply
actions taken. Ensure
corrective action with
informational materials are
impervious overages.
available to guarantee
A summary report will
accessibility outside of office
be given to DEQ.
hours. Through tracking and
2. Once established
2. Annually
2. Number of projects
inspections chronic violators will
monitor the low
in violation and
be identified.
density projects to
Permit Years 1-5
remedy established.
ensure the projects
(FYI 9/20 — FY23/24)
have not expanded
into a high density
classification thus
needing a SCM.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 54
Table 20: Post Construction Site Runoff Control BMPs
3. Provide educational
3. Continuous
3. Number of
materials to the
materials handed out.
general public about
Permit Years 1-5
low density
(FYI 9/20 — FY23/24)
development such as,
but not limited to,
during the issuance of
zoning permits,
distributed through
mailings, social media,
and at events.
43.
Documentation — High Density
Ensure tracking and records are
1. Maintain an
1. Continuous
1. Inventory of high
maintained on projects to ensure
inventory of all
density projects
that upon granting of final CO
developments and
Permit Years 1-5
completed: Yes or No,
and follow-up inspection
redevelopments
(FY19/20—FY23/24)
status.
impervious overages can be
(public and private)
determined and corrective actions
with SCMs. Update
taken. Ensure informational
inventory as sites are
materials are available to
reviewed, approved,
guarantee accessibility outside of
and constructed.
office hours. Through tracking
2. Prior to Certificate
2. Once prior to CO.
2. Number of recorded
and inspections chronic violators
of Occupancy is
plats and deeds to
will be identified.
granted deed
Permit Years 1-5
include name of
restrictions and access
(FYI 9/20 — FY23/24)
project, type of
easement plat shall
Depends on when
document, and
specify impervious
project is nearing
impervious limits.
limitations and be
completion.
recorded.
3. Provide educational
3. Continuous, such as,
3. Number of
materials to
but not limited to,
informational
developers about high
during the issuance of
materials are handed
density development.
zoning permits,
out.
At a minimum,
distributed through
hyperlinks will be
mails, social media, and
maintained on the
at events.
Town's web page
directed to the
Permit Years 1-5
Ordinance and to the
(FYI 9120 — FY23/24)
BMP Design Manual.
4. Establish links to all
4. Annually
4. Items placed on the
ordinances, manuals,
webpage: Yes or No,
policies, checklist,
Permit Years 1-5
Status,
design standards,
(FY19/20 — FY23/24)
and/or other materials.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 55
Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.6: Fecal Coliform Reduction
Ref.
Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H
.1017(7). At a minimum, the program shall include: (a) A pet waste management component, which maybe
achieved by revising an existing litter ordinance, and (b) An on -site domestic wastewater treatment system
component, if applicable, which may be coordinated with local county health department, to ensure proper
operation and maintenance of such systems.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Im lementation
Metric
44.
Fecal Coliform Reduction
1. This permit requirement will be
1. Establish a Pet
1. Permit Year 1
1. Pet Waste
met once the Post -Construction
Waste Ordinance to
Ordinance established:
Stormwater Ordinance is adopted,
address
(FY19/20)
Yes or No, Status.
see references provided in Table
environmental
19. Fecal Coliform is a water
stressors,
quality stressors. Protective
2. Establish a Waste-
2, Permit Year 1
2. Waste water
measures will be established
water treatment
treatment system
through adoption of a pet waste
ordinance to address
(FY19/20)
Ordinance was
and waste water treatment system
environmental
established: Yes or
ordinances. The control of pet
stressors.
No, Status.
waste and waste -water treatment
system will mandated in the
NPDES Phase H Stormwater
Ordinance.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 56
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the
Town of Rutherford College municipal facilities and operations. Pollution prevention and good
housekeeping is accomplished through the implementation of seven required programs, which
collectively address the ultimate goal of preventing or reducing pollutant runoff from municipal
operations such as park and open space maintenance, fleet and building maintenance, new construction
and land disturbances, and municipal storm sewer system maintenance.
Pollution prevention and good housekeeping for municipal operations includes the following programs:
1. Municipal Facilities Operation and Maintenance Program
2. Spill Response Program
3. MS4 Operation and Maintenance Program
4. Municipal SCM Operation and Maintenance Program
5. Pesticide, Herbicide and Fertilizer Management Program
6. Vehicle and Equipment Cleaning Program
7. Pavement Management Program
The Town of Rutherford College will manage, implement and report the pollution prevention and good
housekeeping BMPs as specified in Table 21 below for each required program. In response to the
inefficiencies identified in the MS4 Inspection Report, Permit Citations H.G.2.a., the Town had
maintained an inventory of municipal facilities, but had not determined which facilities were at risk to
generate polluted stormwater runoff. A list of these possible polluters will be established.
An O & M program for the facilities, SCMs, catch basins and conveyance systems has not be created to
date (II.G.2.b, ILG.2.e, and ILG.2.fJ. After the acceptance of the SWMP and in Permit Year One, an O
& M program will be established. (BMP 45). Furthermore, the municipal facilities and SCMs were being
inspected annually, as required per DEQ, but did not include documentation for potential stormwater
impacts (H.G.2.b. and II.G.21.). Incorporated in the O & M program, staff will be trained to determine
appropriate operations and maintenance for facilities and SCMs. To date staff had no training in this area.
The Town of Rutherford College staff did not perform street maintenance, including cleaning of catch
basins and stormwater conveyances (H.G.2.e).
H.G.2.d states that "The Town of Rutherford College did not evaluate BMPs based on their pollutant
removal" in reference to streets, roads, and public parking lot maintenance. Several of the BMPs below
address this issue by developing, adopting, and maintaining procedures that focus on pollutant removal in
these impervious areas. Permit Reference: 3.7.7, BMP's 58-61 address this prior lack of evaluation and
program implementation. BMP 58 focuses on setting schedules and requirements for street/parking lot
sweeping. BMPs 59 and BMP 60 focuses on minimizing and collecting litter/debris, with BMP 59.13.2
working in part as a community outreach program. BMP 61 addresses procedures for cleaning the oils,
fluids, and debris that can come from car accidents by utilizing the developed standard spill procedures as
necessary according to H.G.2.c.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 57
In the audit, II.G.2.e addresses the prior lack of maintenance of the Town's storm sewer system, Permit
Reference, 3.7.3, BMP's 48-51 focus on the training, inspection, and maintenance of said system. BMP
48 develops the required O&M plan which defines procedures/schedules, BMP 49 trains maintainers on
the correct procedure, BMP 50 focuses on inspection along with its documentation, and BMP 51
addresses the audit problem itself by performing the maintenance on the system with documentation.
Previously, the use of pesticides, herbicides, and fert liters in municipal facilities was not well tracked or
managed as stated in II.G.2.i. Permit Reference, 3.7.5, BMP 54 focuses to ensure all staff using
pesticides, herbicides, and fertilizers are officially certified and following appropriate (minimal) usage.
BMP 55 focuses on tracking contractor certification as well as the copies of permits of both municipal
staff and contractors.
II.G.2.j. addresses inconstant/lacking training for
municipal
employees in regards to
good housekeeping
and pollution practices. This is addressed in: 46.B.5, 47.B.4,
49.B.1 BMP 53.B.5, 54.B.1,
56.B.2, 57.b.3,
61.b.1, and 45.b.l. Each of these BMPs focusing
on each of
the 7 programs required
by the permit.
II.G.2.k. addresses a lack of measures regarding correct waste disposal and cleaning of municipal
vehicles/equipment. BMP 56 focuses on the washing side of the problem, addressing training, protocol,
requirements, and options for municipal vehicle operators. BMP 57 focuses on the other side of the issue,
ensuring that vehicle maintenance facilities are correctly disposing of waste and that permitting is
correctly followed to ensure MS4 compliance.
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
3.7.1: Municipal Facilities Operation and Maintenance Program
Ref.
Measures to manage facilities that are owned and operated by the permittee and have the potential for
generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities;
perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard
documentation; provide staff training on general stormwater awareness and implementing pollution prevention
and good housekeeping ractices.
A
I B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
I r lementation
Metric
45.
Municipal Facilities Operation & Maintenance (O & M) Plan
1. Develop an O & M
1. Permit Year 1
1. Was the O & M
plan. The plan will
Plan developed, Yes or
define required
(FY19/20)
No, Status.
procedures per facility
to inspect, maintain
and evaluate.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 58
Table 21: Pollution Prevention and Good Housekeeping BMPs
An O & M Plan must be
2. Adopted the written
2. Permit Year 1
2. Was the O & M
developed, adopted and
O & M Plan as
Plan adopted, Yes or
maintained to define the
developed in Permit
(FY19/20)
No, Status.
expectations of the municipal
Reference 3.7.1, BMP
facilities which are subject to
45.13.1.
3. Administer the O &
3. Continuous,
3. Number of
stormwater/MS4 regulations. The
O & M plan will provide
M Plan as referenced
following development
municipal facilities
reference to the expected
in BMP 45.13.1.
and adoption of the O
inspected; Note any
documents to correct permit
& M Plan location in
plan changes that are
municipal facilities. Each
BMP 45.1391 and 2.
needed. All
municipal facility in which this is
amendments are to be
applicable will adopt an O & M
Permit Years 2-5
approved by DEQ.
plan. The adoption of a plan
(FY20/21 — FY23/24)
entails signing a legally binding
document that defines the party
charged with ensuring that the
facility is correctly maintained
and documentation of the
maintenance is adequate. The
documents will also define the
procedures in how the facility will
be maintained.
46.
Municipal Facilities
The municipal facilities operation
1. Verify the existing
1. Permit Year 1
1. Is the facility list
and maintenance program will
list of facilities is
complete: Yes or No,
ensure the facilities are being
correct by using tax
(FY19/20)
Status,
managed/maintained in a way that
records and Town
does not negatively impact water
data. Field visits may
quality. The facilities will be
be needed if data is not
maintained in a scheduled and
clear.
well defined manner by
2. Use tax data and
2. Permit Year 1
2. Number of potential
performing routine inspections. If
facility visits to
pollutant/spill risk
a facility is subject to SPCC
determine if the
(FY19/20)
facilities.
requirements, then specific
facility has a potential
inspection procedures will be
pollutant and/or spill
completed per the SPCC
risk.
3. Perform facility
3.. Annually
3. Number of facilities
requirements.
inspections to insure
inspected and dates
MS4 municipality is
Permit Years 1-5
inspected;
performing good
(FY19/20-FY23/24)
Number of SPCC
housekeeping
permitted facilities
measures.
inspected.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 59
Table 21: Pollution Prevention and Good Housekeeping BMPs
4. Document and
4. Annually
4. Number of issues
correct issues found
identified/recorded;
during inspections. If
Permit Years 1-5
Number of corrective
a facility is subject to
(FY19/20-FY23/24)
actions taken
SPCC requirements,
(SPCC permitted
then ensure the correct
facilities and non -
documentation is in
SPCC facilities).
place for compliance
with the
regulation/requirement
s.
5. Train municipal
5. Annually
5. Document and
facility staff on proper
report number of staff
stormwater awareness
Permit Years 1-5
trained.
and good
housekeeping
(FY 19/20 — FY23/24)
methods.
Permit
3.7.2: Spill Response Program
Ref.
Measures for facilities and operations that store and/or use materials that have the potential to contaminate
stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on
spill response procedures.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
47.
Spill Response
Spill response program for
1. Develop a written
1. Permit Year 1
1. Were the procedures
facilities and operations that store
spill response
created: Yes or No,
and/or use materials. The program
procedures plan
(FY19/20)
status summary,
will be designed in a way that
according to the
tracks likely polluters, as well as,
Permit Citation in
designate the procedures/materials
NPDES MS4 audit.
required for spill response in
2. Adopt the spill
2. Permit Year 1
2. Plan adopted: Yes
those facilities. The spill response
response procedures
or No, status summary
plan is an internal policy
plan as defined by
(FY19/20)
Date of adoption,
document; therefore would need
Permit Reference
to be put in place once completed.
3.7.2, BMP 47.B.1.
3. Maintain spill
3. Annually
3. Number of updates
response procedures in
to the plan and reason
response to problems
Permit Years 1-5
for update.
that may arise from
(FY19/20-FY23/24)
implementation of spill
procedures.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 60
Table 21: Pollution Prevention and Good Housekeeping BMPs
4. Train staff of spill
4. Annually
4. Document and
response procedures,
report number of staff
Permit Years 1-5
trained; Number of
(FY19/20-FY23/24)
facilities trained.
5. Respond in a timely
5. Continuous,
5. Number of issues
manner to spills as
following the
identified — document
they occur and manage
establishment of the
when and where;
the spills following
plan in Permit Year 1.
Number of corrective
established spill
actions taken,
procedures.
Permit Years 1-5
documenting type of
(FY19/20-FY23/24)
spill.
Permit
3.7.3: MS4 Operation and Maintenance Program
Ref.
Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation
and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections,
maintain the collection system including catch basins and conveyances; and establish specific frequencies,
schedules, and standard documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Im lementation
Annual Reporting
Metric
48.
MS4 Operation & Maintenance (O & M) Plan
An O & M Plan must be
1. Develop an O & M
1. Permit Year 1
1. Was the O & M
developed, adopted and
plan to define required
Plan developed: Yes
maintained to follow the
procedures to schedule
(FY19/20)
or No, Status.
requirements of the MS4 NPDES
inspections, perform
Phase II Stormwater collection
maintenance and
system permit. The O & M plan
evaluations of the
must also be submitted to the
stormwater collection
DEQ for approval.
system,
2. Submit the
2. Permit Year 1
2. Was the O & M
developed O & M plan
plan approved by
to DEQ for approval.
(FY19/20)
DEQ: Yes or No,
Status,
3. Adopted the written
3. Permit Year 1
3. Was the O & M
O & M Plan as
Plan adopted, Yes or
developed in Permit
(FY19/20)
No, Status.
Reference 3.7.3, BMP
48.B.1,
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 61
Table 21: Pollution Prevention and Good Housekeeping BMPs
4. Administer the O &
4. Continuously,
4. Number of MS4
M Plan as references
following development
inspections completed;
in BMP 48.B.1
and adoption of the O
Number of corrections
& M Plan location in
needed based on
BMP 48.13.1 and 2.
inspection findings;
Note any plan changes
Permit Years 2-5
that are needed.
(FY20/21- FY23/24)
49.
MS4 Training
Provide MS4 training to
1. Hold MS4 training
1. Annually
1. Number of
municipal and contracted staff to
events to educate staff
events/personnel
minimize pollutants in the
on stormwater
Permit Years 1-5
trained; provide
stormwater collection system and
awareness and
(FY19/20-FY23/24)
summary of topics
prevent unnecessary damage and
pollution prevention.
covered during
wear on the system.
training.
50.
MS4 Inspection
MS4 inspections to ensure
1. Inspect and maintain
1. Continuous
1. Number of catch
clogged lines, non-functioning
the MS4 infrastructure
basins and
SCMs, and drainage inadequacies
such as pipes, major
Permit Years 1-5
conveyances
are identified.
outfalls, stormwater
(FY19/20-FY23/24)
inspected; Number of
conveyances, and
issues report.
basins to ensure
functionality.
51.
MS4 Maintenance
MS4 inspections to ensure
1. Catch basin and
1. Continuous, as
1. Number of catch
clogged lines, non-functioning
conveyance system
problems are
basins and conveyance
basins, and drainage inadequacies
maintenance activities
identified.
systems cleaned.
are repaired. If the municipality
are performed
cannot reasonably maintain issues
periodically or as
Permit Years 1-5
with MS4 infrastructure found
needed.
(FY19/20-FY23124)
that year, it can be contracted out
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 62
Table 21: Pollution Prevention and Good Housekeeping BMPs
to licensed engin
chooses to do so.
Records are to be
maintained in Public
Works' automated
work order system
and/or by a GIS
application (Permit
Reference 3.4.4, BMP
26) or other applicable
record keeping
Permit Years 1-5
(FY19/20-FY23/24)
complMe d work order
tickets and/or GIS map
updates.
Permit 3.7.4: Municipal SCM Operation and Maintenance Program
Ref. Measures to manage municipally -owned, operated, and/or maintained structural SCMs that are installed for
compliance with the permittee's post -construction program. The permittee shall maintain a current inventory
of SCMs, perform SCM inspections and maintenance, and shall establish specific frequencies, schedules, and
documentation.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
52. I Municipal SCMs Operation &Maintenance (O & M) Plan
Measures to manage (inspect
and/or clean) municipally -owned,
operated, and/or maintained
structural SCMs. This will entail
following the schedule and
procedures defined in the O & M
Plan once developed and adopted.
1. Develop an O & M
plan that will define
required SCMs
procedures to inspect,
maintain and evaluate
structures.
1. Permit Year 1
(FY19/20)
1. Was the O & M
Plan developed, Yes or
No, Status.
2. Adopted the written
2. Permit Year 1
2. Was the O & M
O & M Plan as
Plan adopted, Yes or
developed in Permit
(FY19/20)
No, Status.
Reference 3.7.4, BMP
52.B.1,
3. Administer the O &
3. Continuous,
3. Number of
M Plan as referenced
following development
municipal SCMs
in BMP 52.13.1.
and adoption of the O
inspected; Note any
& M Plan location in
plan changes that are
BMP 52.13.1 and BMP
needed. All
52.13.2
amendments are to be
approved by DEQ.
Permit Years 2-5
(FY20/21-FY23/24)
53. Municipal SCMs
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 63
Table 21: Pollution Prevention and Good Housekeeping BMPs
The municipal SCM/s operation
1. Verify the existing
1. Permit Year 1
1. Is the SCM list
and maintenance program will
list of municipal SCMs
complete: Yes or No,
ensure the structures are being
is correct by visiting
(FY19/20)
Status
managed/maintained in a way that
the sites to determine
(Location and type to
does not negatively impact water
type and condition.
be documented).
quality. The SCMs will be
Use aerial photography
maintained in a scheduled and
in conjunction with
well defined manner defined by
Town records to
the O & M.
determine SCM
location/ ownership.
2. Maintain Inventory
2. Continuous
2. Number of SCMs
of municipally owned
added, with type of
SCMs. Add all new
Permit Years 1-5
each SCM, date,
SCMs as they are
(FY19/20-FY23/24)
location documented.
constructed.
3. Perform annual
3. Annually
3, Number of SCMs
inspection and
maintenance of
Permit Years 1-5
municipally owned
(FY19120-FY23/24)
SCMs to ensure the
operation and
maintenance
agreement is being
followed.
4. Document and
4. Annually
4. Number of issues
correct issues found
identified/recorded;
during inspections.
Permit Years 1-5
Number of corrective
(FY19/20-FY23/24)
actions taken.
5. Train municipal
5. Annually
5. Document and
staff on SCM
report number of staff
housekeeping.
Permit Years 1-5
trained, training
(FY19/20-FY23/24)
date(s) and topics
covered.
Permit
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
Ref.
Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide
routine pollution prevention and chemical use, storage and handling training, and shall ensure compliance with
permits and applicator certifications.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Im lementation
Annual Reporting
Metric
54.
1 Pesticide, Herbicide and Fertilizer Training to Staff
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 64
Table 21: Pollution Prevention and Good Housekeeping BMPs
Measures to minimize water
1. Provide training to
1. Annually
1. Number of
quality impacts from the use of
staff on the use,
events/personnel
landscape chemicals. The only
storage and handling
Permit Years 1-5
certified.
staff who will be allowed to
to get officially
(FY19/20-FY23/24)
utilize pesticides, herbicides,
certified. The training
and/or fertilizers will be certified
will/should include
individuals who use methods to
methods of using
minimize the amounts used.
minimal chemicals to
reduce harmful effects,
especially around
SCM maintenance.
55.
Pesticide, Herbicide and Fertilizer Compliance
Ensure compliance with permits
1. Maintaining copies
1. Annually
1. Number of certified
and certifications for the
of licenses /
personnel.
administering of pesticides,
certifications of all
Permit Years 1-5
herbicides and fertilizer to ensure
staff and contractors
(FY19/20-FY23/24)
application of product is less
who use landscape
impactful to stormwater runoff.
chemicals.
Only certified
landscapers/sprayers are the ones
applying pesticides, herbicides
and fertilizers
Permit
3.7.6: Vehicle and Equipment Cleaning Program
Ref.
Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle
and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities
subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution
prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and
documentation.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Im lementation
Metric
56.
1 Vehicle and Equipment Cleaning
DRAFT NCS000480 SVJMP
Town of Rutherford College
September 21, 2019
Page 65
Table 21: Pollution Prevention and Good Housekeeping BMPs
Prevent or Minimize
1. Establish
1. Permit Year 1
1. Was the protocol
Contamination of Stormwater
appropriate protocol
established: Yes or No,
Runoff from all areas used for
for containing and
(FY19/20)
status.
Vehicle and Equipment Cleaning.
disposing of vehicle
wash water. Wash
water can be directed
to the sanitary sewer or
to vegetated areas.
Where cleaning
operations cannot be
performed as described
above and when
operations are
performed in the
vicinity of a storm
drainage collection
system, the drain is to
be covered with a
portable drain cover
during cleaning
activities. Any excess
standing water shall be
removed and properly
handled prior to
removing the drain
cover. OR another
acceptable method is
installation of a SCM
to capture and treat the
wash water runoff.
2. Provide routine
2. Continuously,
2. Number of training
pollution prevention
following the
events/personnel
training to staff,
establishment of the
trained.
protocol located in
BMP 563.1.
Permit Years 1-5
(FY19/20-FY23/24)
3. Wash all municipal
3. Continuous
3. Method of vehicle
- light vehicles,
and equipment
emergency vehicles
Permit Years 1-5
washing documented
and equipment using
(FY19/20-FY23/24)
to include one of the
an appropriate method
methods listed in BMP
listed in BMP 56.B.1.
56.13.1.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 66
Table 21: Pollution Prevention and Good Housekeeping BMPs
57.
Vehicle and Equipment Maintenance
Measures to ensure that vehicles
1. Ensure the Town
1. Permit Years 1
1. Log of industrial
maintained at municipal facilities
has obtained a NPDES
permits and status.
have waste (included, but not
industrial permit for all
(FY19/20)
limited to, oils, any running
subject municipal
fluids, batteries, belts and other
facility operations
non -fluid vehicle waste) must be
(obtaining said permit
disposed of following DEQ
if a facility is found to
requirements.
be needing one).
2. Perform waste
2. Annually
2. Number of
inspections.
inspections and
Permit Years 1-5
maintenance actions to
(FY19/20-FY23/24)
include date and
location.
3. Provide routine
3. Annually
3. Number of training
pollution prevention
events; number of
and waste management
Permit Years 1-5
personnel trained.
training to staff.
(FY19/20-FY23/24)
Permit
3.7.7: Pavement Management Program
Ref.
Measures to reduce pollutants in stormwater runoff from municipally -owned streets, roads, and parking lots
within the permittee's corporate limits. The permittee shall implement measures to control litter, leaves, debris,
particulate and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and
documentation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Im lementation
Annual Reporting
Metric
58.
Street and Parking Lot Sweeping
Measures to reduce pollutants in
1. Street/curb and
1. Quarterly
1. Total number of
stormwater runoff from
municipally -owned streets, roads,
gutter sweeping an
operational task
Permit Years 1-5
lane miles swept.
and parking lots within the
performed.
(FY19/20-FY23/24)
ermittee's corporate limits.
59.
Litter Management
Collect litter in public areas and
1. Parking lots public
1. Continuous
1. Number of full time
parking lots to reduce negative
waste receptacles are
employees
impacts on water quality.
emptied on a weekly
Permit Years 1-5
responsible;
basis.
(FY19/20-FY23/24)
Number of trash bags
used.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 67
Table 21: Pollution Prevention and Good Housekeeping BMPs
2. All other litter
2. Annually
2. Number of
collection is performed
collection events and
on an as -needed basis
Permit Years 1-5
amount of trash
utilizing available staff
(FY19/20-FY23/24)
collected/disposed of
or community
for each event
volunteers.
(pounds);
Number of staff and/or
volunteers.
60.
Leaf Collection
Implement measures to control
1. Leaves that have
1. Continuous
1. Number of bags
leaves and debris within the
been bagged are
collected.
municipal Town limits (to include
collected by request
Permit Years 1-5
all properties).
through the contracted
(FY19/20-FY23/24)
garbage collection
company. Citizen can
request pick up
through Town Public
Works Department.
61.
Vehicle Pollutant Management
Measures to prevent and minimize
1. Train first
1. Annually
1. Number of first
contamination of stormwater
responders for
responders (staff)
runoff from vehicle pollutants
minimizing, collecting
Permit Years 1-5
trained and date of
following an accident.
and disposing of fluids
(FY19/20-FY23/24)
training.
and other vehicular
pollutants following an
accident.
2. Continue equipping
2. Annually
2. Amount of materials
the first responder
used/replaced in kits.
vehicles with spill kits
Permit Years 1-5
and material
(FY19/20-FY23/24)
containment tools.
3. Public Education to
3. Annually
3. Number of materials
include information
handed out.
about vehicle leaks in
Permit Years 1-5
distributed materials
(FY19/20-FY23/24)
and other educational
resources. Following
BMP Permit Reference
3.2 outreach to target
audiences for
guidance.
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 68
Table 21: Pollution Prevention and Good Housekeeping BMPs
4. Elicit Discharge
4. Annually
4. Number of issues
enforcement for
documented; number
significant vehicle
Permit Years 1-5
corrected.
leaks from parked cars.
(FY19/20-FY23/24)
Reference Permit
Reference 3.4.2 &
3.4.3
DRAFT NCS000480 SWMP
Town of Rutherford College
September 27, 2019
Page 69