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Home My WebLink AboutNCS000559_Draft SWMP_20220803Draft Stormwater Management Plan (SWMP) Town of Clayton August 2022 think NATURAL REsouRcEs Town of CLAYT'O'N STORMWATER Table of Contents PART1: INTRODUCTION............................................................................................................................1 PART 2: CERTIFICATION.............................................................................................................................2 PART 3: MS4 INFORMATION.....................................................................................................................3 3.1 Permitted MS4 Area..................................................................................................................... 3 3.2 Existing MS4 Mapping..................................................................................................................4 3.3 Receiving Waters..........................................................................................................................4 3.4 MS4 Interconnection....................................................................................................................5 3.5 Total Maximum Daily Loads(TMDLs)..........................................................................................5 3.6 Endangered and Threatened Species and Critical Habitat.......................................................... 6 3.7 Industrial Facility Discharges....................................................................................................... 6 3.8 Non-Stormwater Discharges........................................................................................................6 3.9 Target Pollutants and Sources..................................................................................................... 7 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION..................................................9 4.1 Organizational Structure..............................................................................................................9 4.2 Program Funding and Budget....................................................................................................11 4.3 Shared Responsibility.................................................................................................................11 4.4 Co-Permittees.............................................................................................................................12 4.5 Measurable Goals for Program Administration........................................................................12 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM.....................................................................16 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM.........................................................20 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM...............................................22 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM................................................................25 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM......................................................27 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS........................................32 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 Plan (SWMP) is to establish and define the means by which the Town of Clayton (Town) 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 Clayton 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 NCS000559, 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 Clayton and located within the corporate limits and ETJ of the Town of Clayton. In preparing this SWMP, the Town of Clayton 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. The six minimum measures the Town is required to address are the following: • Public Education and Outreach • Public Involvement and Participation • Illicit Discharge Detection and Elimination (IDDE) • Construction Site Runoff Controls • Post -Construction Runoff Controls • Pollution Prevention and Good Housekeeping for Municipal Operations DRAFT NCS000559 SWMP Town of Clayton August 2022 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 ranking elected official. ❑X I am a principal executive officer for the permitted MS4. ❑ I am a duly authorized representative for the permitted MS4 and have attached the authorization made in writing by a principal executive officer or ranking elected official which specifies me as (check one): ❑ A specific individual having overall responsibility for stormwater matters. ❑ A specific position having overall responsibility for stormwater matters. Signature: Print Name: Richard D. Coppola, PE, MPA, CFM Title: Interim Town Manager Signed this day of August 2022 . DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 2 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This SWMP, and the MS4 permit, applies throughout the corporate limits and the ETJ (extra -territorial jurisdiction) of the Town of Clayton, including all regulated activities associated with the discharge of stormwater from the MS4. As of July 2022, the Town's current corporate area is 16.08 square miles; the Town's ETJ and zoning jurisdictional area is 46.33 square miles. The Town's corporate limits and ETJ are located within Johnston County, with a small portion located in Wake County. The following map (Figure 1) shows the corporate limits and the ETJ of the Town of Clayton as of July 2022. Additionally, this map is updated regularly and can viewed on the Town's GIS webpaEe. Figure 1: Town of Clayton Corporate Limits and ED as of July 2022 DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 3 3.2 Existing MS4 Mapping The current MS4 mapping consists of both closed channel and open channel vegetive conveyance. Stormwater is conveyed through a combination of pipes, curbs, gutters, ditches, swales, drop inlets, catch basins, culverts, outfalls, bridges, and overland sheet flow. Additionally, the MS4 mapping includes an inventory of both public and privately maintained stormwater control measures (SCMs). For most of the MS4 mapped drainage features, identifying information such as type of material, pipe diameter, culvert dimensions, and inverts is included. The SCMs include the type and location, and when available, reference to the recorded Operation and Maintenance (O&M) Manual. To adequately prepare for Capital Improvement Program (CIP) needs as well as ensure the safety and well-being of the residents within the Town's corporate limits and ETJ and our down -stream community neighbors, the Town has identified finalizing GIS mapping of the Town's stormwater system and developing a Town wide Stormwater Master Plan as major priorities within the next five (5) years. The Town's MS4 GIS map can be found here. Table 1: Summary of MS4 Mapping (as of 2021 annual report) Percent of MS4 Area Mapped 65 No. of Major Outfalls* Mapped 193 total *An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g., a ditch) 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 receiving waters within the Town of Clayton corporate limits and ETJ are located solely within the Neuse River Basin. Table 2, listed below, identifies an inventory of receiving streams within the MS4 area. The stream index number, water quality classification, and 303(d) list of parameters of interest are noted in Table 2. 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 DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 4 Table 2: Summary of MS4 Receiving Waters Receiving Water Name Stream Index / AU Number Water Quality Classification 303(d) Listed Parameter(s) of Interest Big Arm Creek 27-38-1 C; NSW n/a Little Creek 27-43-12 C; NSW Benthos (Nar, AL, FW) Marks Creek 27-38 C; NSW n/a Neuse River 27-(36) 1 WS-V; NSW I Copper (7ug/I, AL, FW); Zinc (50ug/I, AL, FW) Neuse River 27-(38.5) 1 WS-IV; NSW I n/a 3.4 MS4 Interconnection The Town of Clayton MS4 is not interconnected with another regulated MS4 and directly discharges to the receiving waters as listed in Table 2 above. The MS4 does interconnect with NCDOT's statewide TS4 and includes the following: 1. The interconnection is receiving stormwater from the NCDOT TS4. The number of interconnections was not able to be determined using the data that is currently available. 2. The interconnection is discharging stormwater into the NCDOT TS4. The number of interconnections was not able to be determined using the data that is currently available. 3.5 Total Maximum Daily Loads (TMDLs) The TMDLs) listed in Table 3 below have been approved within the MS4 area, as determined by the map and list provided on the NCDEQ 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. Table 3: Summary of Approved TMDLs Water Body TMDL Pollutant(s) of Stormwater Waste Water Quality Recovery Name Concern Load Allocation (Y/N) Program (Y/N) Neuse River Total Nitrogen N N Estuary DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 5 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 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 Elliptio steinstansana Tar River spinymussel Clams Endangered Alasmidonta heterodon Dwarf wedgemussel Clams Endangered Noturus furiosus Carolina madtom Fishes Endangered Elliptio lanceolata Yellow lance Clams Threatened Fusconaia masoni Atlantic pigtoe Clams Threatened Necturus lewisi Neuse River waterdog Amphibians Threatened 3.7 Industrial Facility Discharges The Town of Clayton 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. Table 5: NPDES Stormwater Permitted Industrial Facilities Permit Number Facility Name (owner) NCG030690 Clayton Machine Development Center (Caterpillar Inc.) NCG030211 Caterpillar Incorporated (same) NCG060402 Novo Nordisk-DAPI-US (Novo Nordisk Pharmaceuticals Industries LP) NCG060048 Novo Nordisk Pharmaceuticals Industries, LP (same) NCG060039 Grifols Therapeutics LLC (same) NCG200498 Renew Recycling LLC (same) NCG110080 Little Creek Water Reclamation (Town of Clayton) 3.8 Non-Stormwater Discharges The water quality impacts of non-stormwater discharges have been evaluated by the Town of Clayton as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 6 Street washing discharges are addressed under the Pavement Management Program in Part 10 of this SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the Town of Clayton. Wash water associated with car washing that does not contain detergents or does not discharge directly into the MS4 is considered incidental. Residential and non-profit car washing is exempt from the Town's IDDE ordinance. However, these types of non-stormwater discharges that do contain detergents have been evaluated by the Town of Clayton to determine whether they may significantly impact water quality. It has been determined by the Town of Clayton that residential and non-profit car washing may impact water quality, but they occur infrequently enough it does not need to be limited at this time. This SWMP addresses measures taken by the Town of Clayton to reduce the target pollutants of wash water associated with residential and non-profit car washing. Table 6: Non-Stormwater Discharges Non-Stormwater Discharge Water Quality Impacts Water line and fire hydrant flushing 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 crawl space pumps Incidental Footing drains Incidental Lawn watering Incidental Residential and charity car washing Possible Flows from riparian habitats and wetlands Incidental Dechlorinated swimming pool discharges Incidental Street wash water Possible Flows from firefighting activities Incidental 3.9 Target Pollutants and Sources In addition to those target pollutants identified above, the Town of Clayton 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/sources/targeted audiences attributed to each pollutant and identifies the associated DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 7 SWMP program(s) that address each. In addition, the Town of Clayton has evaluated schools, homeowners and businesses as target audiences that are likely to have significant stormwater impacts. Table 7: Summary of Target Pollutants and Sources Target Pollutant(s) Likely Source(s)/Target SWMP Program Addressing Target Audience(s) Pollutant(s)/Audience(s) Sediment Erosion and Construction Public Education & Outreach Site Runoff/ Residents, Construction Site Runoff Controls - Erosion Businesses, Contractors, Control Ordinance ; Illicit Discharge Ordinance Engineers, and Private (IDDE) Developers Pool Discharge Residents and Businesses Public Education & Outreach Yard Waste Inappropriate Disposal/ Public Education and Outreach; Pollution Residents, Businesses, and Prevention and Good Housekeeping Schools Litter Inappropriate Disposal/ Public Education and Outreach ; Pollution Residents, Businesses, Prevention and Good Housekeeping Schools, and Municipal Pesticides, Improper application/ Public Education and Outreach; Pollution Herbicides, and Residents, Businesses, Prevention and Good Housekeeping Insecticides Schools, and Municipal Household Inappropriate Disposal/ Public Education and Outreach; Illicit Discharge Hazardous Waste Residents, Businesses, and Ordinance (IDDE) Schools Fats, Oils, Greases Inappropriate Disposal/ Public Education and Outreach; Illicit Discharge (FOG) Residents and Businesses Ordinance (IDDE); Pollution Prevention and Good Housekeeping Fecal Coliform Inappropriate Disposal/ Public Education and Outreach; Illicit Discharge Residents, Businesses, and Ordinance (IDDE) Municipal Illicit Discharges Inappropriate Disposal/ Public Education and Outreach; Illicit Discharge Residents, Businesses, Ordinance (IDDE); Pollution Prevention and Schools, and Municipal Good Housekeeping Illegal dumping Inappropriate Disposal/ Public Education and Outreach; Illicit Discharge Residents, Businesses, Ordinance (IDDE) Schools, and Municipal DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 8 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure The Town of Clayton stormwater program is administered by the Engineering Department. The Stormwater Engineer, under supervision of the Engineering Director, manages the daily implementation of the program. Additional contribution is provided by several departments within the organization; Public Works, Water Resources, Parks and Recreation, Fire, Police, and the Executive Team. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 9 Table 8: Summary of Responsible Parties SWMP Component Responsible Position Staff Name Department Stormwater Program Engineering Director Joshua Baird, PE Engineering Administration SWMP Management Stormwater Engineer Vacant Engineering Public Education & Outreach Environmental Kevin Watson, CESSWI Engineering Compliance Specialist Public Involvement & Stormwater Engineer Vacant Engineering Participation Illicit Discharge Detection & Environmental Kevin Watson, CESSWI Engineering Elimination Compliance Specialist Construction Site Runoff Stormwater Engineer Vacant Engineering Control Post -Construction Stormwater Engineer Vacant Engineering Stormwater Management Pollution Prevention/Good Housekeeping for Municipal Environmental Kevin Watson, CESSWI Engineering Operations Compliance Specialist Municipal Facilities Environmental Operation & Maintenance Compliance Specialist Kevin Watson, CESSWI Engineering Program Spill Response Program Environmental Kevin Watson, CESSWI Engineering Compliance Specialist MS4 Operation & Stormwater Engineer Vacant Engineering Maintenance Program Municipal SCM Operation & Stormwater Engineer Vacant Engineering Maintenance Program Pesticide, Herbicide & Environmental Fertilizer Management Compliance Specialist Kevin Watson, CESSWI Engineering Program Vehicle & Equipment Environmental Kevin Watson, CESSWI Engineering Cleaning Program Compliance Specialist DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 10 Pavement Management Assistant Town Engineer Jonathan Jacobs, PE Engineering Program Total Maximum Daily Load Stormwater Engineer Vacant Engineering (TMDL) Requirements 4.2 Program Funding and Budget In accordance with the issued permit, the Town of Clayton 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 the Division annually. The Stormwater Program currently receives funding of approximately $ 500,000 per year; funded through the Town's General Fund. The program has 12 staffed members; 2 full-time stormwater staff and 10 full-time auxiliary staff to provide program support. The Town's MS4 program has recently become administered by Town staff and is still being fully developed. The program is currently under -funded and under -staffed to conduct all the proactive elements of the permit. Further fiscal analysis and investigation will be conducted to further evaluate staff and funding needs. Additionally funding sources, such as a Stormwater Utility Fee, may also be evaluated to reduce the gap in available funding. 4.3 Shared Responsibility The Town of Clayton will share the responsibility to implement the following minimum control measures, which are at least as stringent as the corresponding NPDES MS4 Permit requirement. The Town of Clayton 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 Clayton nor the other entity fully performs the permit obligation. Table 9 below summarizes who will be implementing the component, what the component program is called, the specific SWMP BMP or permit requirement that is being met by the shared responsibility, and whether or not a legal agreement to share responsibility is in place. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 11 Table 9: Shared Responsibilities SWMP BMP or Implementing Entity &Program Name Legal Agreement Permit Requirement (Y/N) Table 13 — BMP #4 Clean Water Education Partnership (CWEP) Y Permit Section 3.2.2 and 3.2.4 4.4 Co-Permittees There are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000559 for the Town of Clayton. Table 10 summarizes contact information for each co-permittee. Table 10: Co-Permittee Contact Information Co-Permittee MS4 Name Contact Person Phone & E-Mail Interlocal Agreement (Y/N) N/A 4.5 Measurable Goals for Program Administration The Town of Clayton will manage and report the following Best Management Practices (BMPs) for the administration of the Stormwater Management Program. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 12 Table 11: Program Administration BMPs 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. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #1 Permit Renewal Application Audit stormwater program 1. Participate in an 1. TBD —Typically Permit 1. N/A implementation for compliance with NPDES MS4 Permit Year 4 the permit and approved SWMP and Compliance Audit, as utilize the results to prepare and scheduled and submit a permit renewal application performed by EPA or package. NCDEQ. 2. Self -audit and 2. Permit Year 5 2. Submit Self -Audit to document any DEMLR (required stormwater program component of permit components not audited renewal application by EPA or NCDEQ package). utilizing the DEQ Audit Template. 3. Certify and submit the 3. Permit Year 5 3. Permit renewal stormwater permit application package renewal application received by DEQ at least (NOI, Self -Audit, and 180 days prior to permit Draft SWMP for the next expiration. 5-year permit cycle). Permit II.AA: Adequate Funding and Staffing Ref. Maintain adequate funding and staffing to implement and manage the provisions of the SWMP and meet all requirements of MS4 permit. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #2 Adequate Funding Perform fiscal and staffing analysis 1. Complete fiscal and 1. Permit Year 1 1. Report monetary and explore options to achieve staffing gap analysis value of gap and staffing adequate program funding in order needs/shortages in to meet all requirements of MS4 Annual Report 2. Identify potential 2. Permit Year 2 2. Report funding permit. funding mechanisms mechanism 3. Implement funding 3. Permit Year 3 3. Implemented? mechanisms Yes/No/Status DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 13 Table 11: Program Administration BMPs I#2 Adequate Staffing Maintain adequate staffing for the 1.Utilize complete 1. Annually during 1. Summary of stormwater program program analysis to budget preparation stormwater positions in determine staffing needs Annual Report. Town wide to meet the intent of this document. Permit II.A.2: Performance and Effectiveness of the MS4 Program . Ref. Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the NPDES MS4 permit. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #4 Permit Renewal Application Audit stormwater program 1. Participate in an 1. TBD —Typically Permit 1. N/A implementation for compliance with NPDES MS4 Permit Year 4 the permit and approved SWMP and Compliance Audit, as utilize the results to prepare and scheduled and submit a permit renewal application performed by EPA or package. NCDEQ. 2. Self -audit and 2. Permit Year 5 2. Submit Self -Audit to document any DEMLR (required stormwater program component of permit components not audited renewal application by EPA or NCDEQ package). utilizing the DEQ Audit Template. 3. Certify and submit the 3. Permit Year 5 3. Permit renewal stormwater permit application package renewal application received by DEQ at least (NOI, Self -Audit, and 180 days prior to permit Draft SWMP for the next expiration. 5-year permit cycle). #5 Annual Self -Assessment Perform an annual evaluation of 1. Prepare, certify, and 1. Annually for Permit 1. Annual Self- SWMP implementation, suitability of submit the Annual Self- Years 1-4 Assessment received by SWMP commitments and any Assessment to NCDEQ NCDEQ no later than proposed changes to the SWMP prior to August 31 each August 31 each year. utilizing the NCDEQ Annual Self- year. Assessment Template. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 14 Table 11: Program Administration BMPs Permit II.A.3: Stormwater Management Plan (SWMP) Ref. Measures to keep this SWMP up to date through the permit period. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #6 SWMP Updates Perform routine updates to the 2. An updated SWMP 1. As determined by the 1. Notate updates within SWMP when necessary, changes are with documented Town or NCDEQ the SWMP in the Annual determined or as conditions change. revisions. Report. Permit II.AA: Stormwater Management Plan (SWMP) Availability Ref. Measures to make the SWMP available to NCDEQ and available to the public. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #7 SWMP Availability Make the SWMP, all revisions, 1. Make the SWMP 1. As requested 1. N/A stormwater ordinance, and other available upon request regulatory mechanisms available to of NCDEQ. 2. Keep the updated 2. January 1, 2023 2. Include a link in the NCDEQ and the public. SWMP in NCDEQ format Annual Report on the Town's website. 3. Upload all necessary 3. As soon as revisions to 3. Include a link in the SWMP updates to the the SWMP are Annual Report Town website and keep a completed, approved, record of revisions. and implemented Make the SWMP, all revisions, 1. Make the SWMP 1. As requested 1. N/A stormwater ordinance, and other available upon request regulatory mechanisms available to of NCDEQ. 2. Keep the updated 2. January 1, 2023 2. Include a link in the NCDEQ and the public. SWMP in NCDEQ format Annual Report on the Town's website. 4. Upload all necessary 3. As soon as revisions to 3. Include a link in the SWMP updates to the the SWMP are Annual Report Town website and keep a completed, approved, record of revisions. and implemented DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 15 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM The Town of Clayton will implement a Public Education and Outreach Program 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. 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 Clayton 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 Target Pollutant/Sources Likely Source(s)/Target Audience(s) Sediment Residents, Businesses, Contractors, Engineers, and Private Developers Pool Discharge Residents and Businesses Yard Waste Residents, Businesses, and Schools Litter Residents, Businesses, Schools, and Municipal Pesticides, Herbicides, and Insecticides Residents, Businesses, Schools, and Municipal Household Hazardous Waste Residents, Businesses, and Schools Fats, Oils, Greases (FOG) Residents and Businesses Fecal Coliform Residents, Businesses, and Municipal Illicit Discharges Residents, Businesses, Schools, and Municipal Illegal dumping Residents, Businesses, Schools, and Municipal The Town of Clayton will manage, implement, and report the following public education and outreach BM Ps. The Town will utilize existing major Town events, such as the annual Square to Square July 4t" Celebrate and Harvest Festival as a platform for stormwater public education and outreach. Additionally, the Town will utilize other Town events throughout the year when opportunities arise such as the Clayton Farm and Community Market. Educational materials will be displayed as well as distributable materials such as brochures and "swag" to promote reducing pollutants in storm water runoff. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 16 Table 13: Public Education and Outreach BMPs Permit II.B.2a-d: 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 provide educational information to identified target audiences on pollutants/sources identified in table 12 above and shall document the extent of exposure of each media, event, or activity, including those elements implemented locally or through a cooperative agreement. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #8 Partnership with CWEP The Town will engage with CWEP to 1. Arrange partnership 1. Each Permit 1. Provide Legal Agreement develop Education and Outreach with CWEP and establish Year Initiatives that will be administered legal agreement. 2. Attend regularly 2. Quarterly 2. Provide schedule of by CWEP. Initiatives will focus on residential, commercial, and school scheduled CWEP meetings meetings attended 3. Outreach initiatives 3. Annually 3. CWEP Annual Report audiences within the MS4 area. #9 Town Sponsored Events/Festivals The Town will distribute information 1. Develop stormwater 1. current 1. Is brochure available? on stormwater during at least one maintenance brochure to Yes/No/Status City sponsored event or festival a hand out at festivals year, such as Square to Square or 2. Coordinate event dates 2. Annually 2. Was CWEP staff available? Harvest Festival. with CWEP to have Yes/No/Status additional persons available to assist in the event 3. Document the number 3. Annually 3. Report the number of of individuals that visited individuals that visited tent. the stormwater tent during the event #10 SCM Educational Signage Educational signage will be added to 1. Locate town -owned 1. See BMP No. 1. See BMP No. 23 Town -owned SCMs that are visible to SCMs and add them to the 23 the public. inventory 2. Develop educational 2. Permit Year 1 2. Report number of signs signage that identifies developed in Annual Reports. SCM, describes it function and notes website 3. Fund and Install signage 3. Permit Year 2 3. Report number of signs installed in Annual Report #11 Describe Target Pollutants and/or stressors DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 17 Table 13: Public Education and Outreach BMPs Maintain a description of the target 1. Document description 1. Permit Year 1 N/A pollutants and/or stressors and likely of the target pollutants in sources Table 12 of this SWMP. 2. Update Table 12, as 2. Annually 2. Report any changes in needed, if any new target Annual Report. pollutants are determined to risk water quality. #12 Describe Targeted Audiences Maintain a description of the target 1. Document description 1. Permit Year 1 N/A audiences likely to have significant of the target audiences in storm water impacts and why they Table 12 in this SWMP. were selected 2. Update Table 12, as 2. Annually 2. Report any changes in needed, if any new target Annual Report. audiences are determined to risk water quality. #13 Describe Residential and Industrial/Commercial Issues Describe issues, such as pollutants, 1. Describe issues for each 1. Permit Year 1 N/A likely sources of those pollutants, type of use. 2. Update list of issues, as 2. Annually 2. Report any changes in impacts, and the physical attributes of stormwater runoff, in their needed if any new Annual Report. education/outreach program. common issues are determined to risk water quality. Permit B.2.e: Town of Clayton Stormwater Web Site Ref. Measures to provide a web site designed to convey the program's message(s) and provide online materials including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit and SWMP. The web page shall also provide developers with all relevant post -construction requirements, design standards, checklists and/or other materials. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #14 Stormwater Page on Town Website Web page will provide information 1. Establish stormwater 1. Permit year 1 1. Link to webpage on the Town's Stormwater Program. web page. 2. Maintain webpage. 2. Quarterly 2. Has quarterly maintenance Information will include applicable ordinances, MS4 permit, SWMP and Verify links are working; occurred for webpage? links to additional stormwater update information. Yes/No 3. Promote website on 3. As appropriate; 3. N/A educational resources. outreach materials and regularly social media. 4. Track monthly visits to 4. Monthly 4. Report monthly visits in the the website. annual report. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 18 Table 13: Public Education and Outreach BMPs Permit B.2.f: Distribute Public Education Materials Ref. Measures for providing public education materials to the identified target audiences in this SWMP. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #15 Social Media Campaign Utilize the Town's various existing 1. Post about targeted 1. Quarterly 1. Report the date of posts in social media pages to reach the pollutants at identified in the annual report. target audience as identified in this Table 12. SWMP. A minimum of one post per quarter will be provided. Permit B.2.g: Maintain 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 Implementation Annual Reporting Metric #16 Stormwater Hotline Promote and maintain and active 1. Update phone number 1. As needed 1. N/A hotline or helpline for Stormwater. on the website and promotional materials, as needed 2. Train all customer 2. Once permit 2. Report number of service staff on cycle; as staffing employees trained. appropriate transferring changes calls to the hotline. 3. Promote hotline on 3. Quarterly 3. Report in annual reports. outreach materials and social media 4. Track hotline calls 4. Monthly 4. Report monthly calls in the received. annual report. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 19 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that complies with applicable State, Tribal and local public notice requirements. The Town of Clayton will manage, implement, and report the following public involvement and participation BMPs. Table 14: Public Involvement and Participation BMPs Permit C.2.b-c: 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 Metric Implementation #127 Online Public Comments Stormwater questions or concerns 1. Promote and maintain 1. Permit Year 1. 1. Established? Yes/No can be entered through an online the online submission Continuously following Number of Submissions submission for on the Town's forms to allow public development. updated website. Comments will be input to be generated. directed to the appropriate Town staff. #18 Stormwater Hotline Promote and maintain and active 1. See BMP #16. 1. See BMP #16. 1. See BMP #16. hotline or helpline for Stormwater (BMP #11). #19 Social Media Outreach Maintain a social media outreach 1. Establish social media 1. Continuously. 1. Report number of program to public educational presence regarding posts in annual reports. materials, promote Town -Sponsor stormwater and provide events, target pollutants, and information on public advertise the stormwater hotline and input opportunities. webpage. #20 Town Sponsored Events/Festival Utilize Town sponsored events to 1. Attend town 1. Annually 1. Report number of promote stormwater education and sponsored events to events in annual reports. allow for public information. promote options for public input and receive direct input during event. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 20 Table 14: Public Involvement and Participation BMPs Permit C.2.a: Volunteer Opportunities Ref. Measures to provide volunteer opportunities designed to promote ongoing citizen participation. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Metric Implementation #21 Storm Drain Marking, Stenciling, or Stamping Coordinate events with school 1. Number of markers 1. Annually. 1. Report number of groups, local HOAs, and conservation installed. markers installed in groups to raise awareness and annual reports. promote ownership within their communities and schools to protect the quality of stormwater. #22 Promote Regional Creek Week CWEP has an annual creek week that 1. Number of hits on 1. Annually. 1. Report number of the Town will advertise through social media social media hits in social media and the Town website. annual reports. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 21 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The Town of Clayton 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. Table 15: Illicit Discharge Detection and Elimination (IDDE) BMPs Permit D.2.b: 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 Annual Reporting Metric Implementation #23 MS4 Mapping Update and Complete the MS4 1. 100% mapping of MS4 1. Year 3 1. Percentage of Mapping area to record a system in Town Limits and ETJ mapping completed in map of all major outfalls, surface annual reports. 2. Maintain current MS4 2. Continuously 2. Yes/No/# of outfalls waters, conveyances, flow direction, and interconnections with other map as new added to current programs. infrastructure is mapping. proposed and accepted by the Town. Permit D.1.c and D.2.a: 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 MS4, including enforcement procedures and actions. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Metric Implementation #24 Maintain Legal Authority Review existing ordinance; update if 1. Review ordinance 1. Annually 1. Report ordinance required to maintain legal authority adoption date and any to prohibit, detect, and eliminate updated performed in illicit connections or discharges, the annual reports. illegal dumping, and spills into MS4. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 22 Table IS: Illicit Discharge Detection and Elimination (IDDE) BMPs Permit D.1.a-f: 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. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Metric Implementation #25 Develop IDDE Standard Procedures Develop and maintain internal 1. Standard Operation 1. Year 1, Continuously 1. Yes/No/Partial procedures for IDDE investigations Procedures documented #26 Dry Weather Flow Inspections — Major Outfalls Perform regular dry weather (no rain 1. Train field staff to 1. Annually 1. Provide the number of in previous 72 hours) outfall perform dry weather dry weather inspections inspections to proactively identify outfall inspections performed in the annual illicit discharges and connections. reports. Permit D.2.e: 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 C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Metric Implementation #27 Record Keeping Establish filing system that enables 1. Track number of illicit 1. Year 1, Continuously 1. Report how many Town staff to report the number of discharge investigations reports of illicit illicit discharge "investigations" discharge were performed. investigated in annual reports. 2. Document date, type, 2. Continuously 2. N/A location, and results of each IDDE investigation. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 23 Table 1S: Illicit Discharge Detection and Elimination (IDDE) BMPs Permit D.2.f: Staff IDDE Training Ref. Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities, may observe an illicit discharge, illicit connection, illegal dumping, or spills. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping, and spills. 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 #28 Staff Training Develop program to educate Town 1. Identify Town staff to 1. Year 1 1. How many Town staff staff of indicators of potential illicit be trained are identified to be discharges/connections and illegal trained? dumping and the appropriate means 2. Schedule staff training 2. Annually 2. How many Town staff of reporting such incidents. sessions were trained? #29 Fact Sheets Hang fact sheet posters in staff 1. Purchase/Develop 1. Year 3 1. Yes/No/Status communal areas for educational educational posters purposes and reminders of basics of 2. Display education 2. Year 3 2. Number of identifying and reporting illicit posters in communal posters/communal areas discharges/connections. areas Permit D.2.h: IDDE Reporting Ref. 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. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #30 Reporting Develop and promote a reporting 1. Promote reporting 1. Quarterly 1. Report number of mechanism for the public and mechanism. targeted audience municipal staff to easily report illicit members reached discharges and establish and through promotion in implement citizen requests. annual reports. 2. Appropriately train 2. Annually. 2. Identify number of staff on IDDE and staff trained in annual reporting mechanisms. reports. 3. Investigate and 3. As reported 3. Identify number of respond to IDDE IDDE complaints in complaints. annual reports. 4. Follow up to verify all 4. As reported and 4. Identify number of IDDE concerns have identified IDDE concerns addressed been by the responsible party. corrected/resolved. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 24 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153, the Town of Clayton relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 and the NCG010000 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 Authority Implementing Entity or Part of Reference Requirement EA Town of Clayton 15A NCAC Town of Clayton Whole Delegated SPCA Program* Chapter 04 * The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at: https://codelibrary.amlegal.com/codes/claytonnc/latest/clayton nc/0-0-0-25704#JD Chapter156. The Town of Clayton also implements the following BMPs to meet NPDES MS4 Permit requirements. Table 17: Construction Site Runoff Control BMPs Permit E.3: 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 Annual Reporting Metric Implementation #31 Municipal Staff Training Train municipal staff who receive 1. Train municipal staff 1. Annually 1. Report the number of calls from the public on the protocols on proper handling of staff trained in annual for referral and tracking of construction site runoff reports. construction site runoff control control complaints. complaints. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 25 Table 17: Construction Site Runoff Control BMPs Permit E.2: Waste Management Ref. Measures to require construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to water quality. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Metric Implementation #32 Maintain Legal Authority Waste Management on construction 1. See BMP #24 1. See BMP #24 1. See BMP #24 sites is captured in the illicit discharge ordinance and can be used as a mechanism of enforcement. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 26 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM 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, which are located within the Town of Clayton and discharge into the MS4. These elements are designed to minimize water quality impacts 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 Clayton implements the following State post -construction program requirements, which satisfy the NPDES Phase II MS4 post -construction site runoff control requirements as Qualifying Alternative Programs (QAPs) in the MS4 area(s) where they are implemented. Table 18: Qualifying Alternative Program(s) for Post -Construction Site Runoff Control Program State QAP Name State Requirements Local Ordinance / Regulatory Mechanism Reference Water Supply Watershed (WS-IV) 15A NCAC 2B Town of Clayton Code of .0620 - .0624 Ordinances — Chapter 155 (155.501) Neuse River Basin Nutrient Sensitive 15A NCAC 2B .0235 Town of Clayton Code of (NSW) Management Strategy Ordinances — Chapter 158 DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 27 N 5mithteld WSV4 Johnston County WSW r Clayton Town Limits Extra -Territorial Jurisdictions 5 :Y Y F F. 1: u{ c l+ybn ay,y h� BSy Y D 0.5 1 2 3 Miles Figure 2: Town of Clayton Water Supply Watershed as of July 2022 The Town of Clayton has existing requirements other than Qualifying Alternative Program(s) for implementation of the NPDES Phase II MS4 post -construction program requirements. These existing requirements are codified in local ordinance(s), and implementation is further defined in guidance, manuals and/or standard operating procedure(s) as summarized in Table 19 below. DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 28 Table 19: Summary of Existing Post -Construction Program Elements Permit Requirements for Municipal Ordinance/Code Reference(s) Date Adopted Plan Review and Approval and/or Document Title(s) 3.6.2(a) Authority Town of Clayton Code of Ordinances — Adopted Chapter 158 (158.002) 11/16/20; effective 1/1/21 3.6.3(a) & 15A NCAC 02H.0153(c) Town of Clayton Code of Ordinances — " Federal, State & Local Projects Chapter 158 (158.003) 3.6.3(b) Plan Review Town of Clayton Code of Ordinances — " Chapter 158 (158.026) 3.6.3(c) O&M Agreement Town of Clayton Code of Ordinances — " Chapter 158 (158.061) 3.6.3(d) O&M Plan Town of Clayton Code of Ordinances — " Chapter 158 (158.060) 3.6.3(e) Deed Town of Clayton Code of Ordinances — " Restrictions/Covenants Chapter 158 (158.043) 3.6.3(f) Access Easements Town of Clayton Code of Ordinances — " Chapter 158 (158.067) Permit Requirements for Municipal Ordinance/Code Reference(s) Date Adopted Inspections and Enforcement and/or Document Title(s) 3.6.2(b) Documentation Town of Clayton Code of Ordinances — Adopted Chapter 158 (158.060) 11/16/20; effective 1/1/21 3.6.2(c) Right of Entry Town of Clayton Code of Ordinances — " Chapter 158 (158.061) 3.6.4(a) Pre -CO Inspections Town of Clayton Code of Ordinances — " Chapter 158 (158.081) 3.6.4(b) Compliance with Plans Town of Clayton Code of Ordinances — " Chapter 158 (158.027) 3.6.4(c) Annual SCM Inspections Town of Clayton Code of Ordinances — " Chapter 158 (158.060) 3.6.4(d) Low Density Inspections Town of Clayton Code of Ordinances — " Chapter 158 (158.060) 3.6.4(e) Qualified Professional Town of Clayton Code of Ordinances — " Chapter 158 (158.027) DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 29 The annual reporting metrics for the post construction program are provided in Table 20: Post Construction Site Runoff Control BMPs below. Table 20: Post Construction Site Runoff Control BMPs Permit F.3.a-e: 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 progress, status, and results. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #33 Standard Reporting Implement standardized tracking, 1. Track number of low 1. Continuously 1. Number of plan documentation, inspections, and density and high -density reviews performed for reporting mechanisms to compile plan reviews performed. low density and high appropriate data for the annual self- density. 2. Track number of low 2. Continuously 2. Number of plan assessment process. Data shall be provided for each Post -Construction/ density and high -density approvals issued for low Qualifying Alternative Program being plans approved. density and high density. 3. Maintain a current 3. Continuously 3. Summary of number implemented as listed in Tables 18 and 19. inventory of low -density and type of SCMs added projects and constructed to the inventory; and SCMs including SCM type number and acreage of or low -density acreage, low -density projects location, and last constructed. inspection date. 4. Track number of SCM 4. Continuously 4. Number of SCM inspections performed. inspections. 5. Track number of low- 5. Continuously 5. Number of low - density inspections density inspections. performed. 6. Track number and 6. Continuously 6. Number and type of type of enforcement enforcement actions actions taken. taken. Permit F.3.a and F.3.c: 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 The QAP requirements are fully met by the existing QAP for post -construction, see references provided in Table 18 DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 30 Table 20: Post Construction Site Runoff Control BMPs Permit F.2.a: 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. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric This permit requirement is fully met by the existing post -construction program, see references provided in Table 19 Permit F.2.c: 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 This permit requirement is fully met by the existing post -construction program, see references provided in Table 19 Permit F.2.g and F.2.i: 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 DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 31 Table 20: Post Construction Site Runoff Control BMPs BMP No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric This permit requirement is fully met by the existing post -construction program, see references provided in Table 19 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the Town of Clayton 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 parks 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 Maintenance Program 7. Pavement Management Program The Town of Clayton will manage, implement, and report the pollution prevention and good housekeeping BMPs as specified in Table 21 below for each required program. Table 21: Pollution Prevention and Good Housekeeping BMPs Permit G.2.a-j: 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 practices. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Metric Implementation #34 Staff Training DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 32 Table 21: Pollution Prevention and Good Housekeeping BMPs Provide staff training to prevent and 1. Identify and schedule 1. Year 1, As staffing 1. Report how many reduce stormwater pollution from staff to be trained. changes, annually. staff trained in annual activities such as park and open reports. space maintenance, fleet and building maintenance, new construction and land disturbance, and stormwater system maintenance. #35 Inventory of Town owned or operated facilities Maintain inventory of facilities and 1. Maintain an updated 1. Year 1 1. Report number of operations owned and operated by inventory of municipal facilities inventoried in the Town with the potential for facilities with the annual reports. generating polluted stormwater potential for generating runoff. polluted stormwater runoff. #36 Inspection and Maintenance of Town Facilities Maintain and implement and 1. Identify inspections 1. Year 1 1. Report number of Inspection and Maintenance needed per type of required inspections Program of all Town Owned or facility. required in annual Operated Facilities. reports. 2. Perform identified 2. Annually 2. Report number of inspections. required inspections in annual reports. 3. Perform maintenance 3. Annually 3. Report required as needed per maintenance performed inspections. in annual reports. Permit G.2.c and G.2.i: 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 #37 Staff Training Provide staff training for those in 1. Identify facilities and 1. Annually 1. Identify required positions that may need to respond staff which require such facilities and staff to contaminated stormwater runoff. training. needing training in annual reports. 2.Train staff 2. Annually 2. Report how many staff were trained in annual reports. #38 Standard Operating Procedures (SOPs) for Spill Response DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 33 Table 21: Pollution Prevention and Good Housekeeping BMPs Develop written SOP(s) for various 1. Identify the various 1. Year 1 1. Report how SOPs are spill responses. situations. needed to be developed in annual reports. 2. Assign staff to develop 2. Year 2 2. N/A SOP(s). 3. Write SOP(s). 3. Year 3 3. Report if SOP(s) have been completed and adopted in annual reports. Permit G.2.b and G.2.i: 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 Implementation Annual Reporting Metric #39 Staff Training Provide staff training for field 1. Identify field 1. Annually 1. How many staff are to personnel on stormwater awareness, personnel to be trained. be trained for MS4 illicit discharge/pollution prevention. 0&M? 2. Provide training 2. Annually 2. How many staff were trained? #40 System Inspections Establish specific frequencies, 1. Establish schedule and 1. Year 1 1. Has schedule and map schedules, and documentation of mapping for routine been established? MS4 inspections of catch basins, inspections Yes/No/Status 2.Perform routine 2. Annually 2. How many inspections drop inlets and conveyances. inspections as scheduled were performed? 3. Identify system 3. Annually 3. How many repairs maintenance/repair were identified? needs 4. Schedule necessary 4. Annually 4. How many repairs system maintenance were completed? Permit G.2.g: 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 Implementation Annual Reporting Metric #41 SCM Inventory and Inspection Develop inventory and inspection 1. Complete Clayton 1. Year 1 1. How many SCMs does schedule of Town owned SCMs owned SCM inventory the Town own? DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 34 Table 21: Pollution Prevention and Good Housekeeping BMPs 2. Develop 2.Year 1 2. Provide inspection annual/routine schedule inspection schedule for Clayton SCMs #42 SCM Maintenance Perform and document routine 1. Perform routine 1. Continuously 1. How many inspections inspections and maintenance of inspections were performed? 2. Document inspections 2. Continuously 2. How many repairs Town owned SCMs and repair needs were scheduled and performed? Permit G.2.h and G.2.i: 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 Implementation Annual Reporting Metric #43 Staff Training Require staff training for those 1. Identify staff 1. Year 1 1. How many staff need involved with pesticide, herbicide, responsible for such to be trained? and fertilizer applications. duties 2. Identify appropriate 2. Year 1 2. How many staff training opportunities obtained and certifications training/certification? Permit G.2.j and G.2.i: Vehicle and Equipment Maintenance 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. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric #44 Staff Training Educate staff on preventing and 1. Identify NPDES 1. Year 1 1. How many NPDES minimizing contaminated industrial permits held industrial permits does stormwater runoff in addition to by the Town. the Town hold? ensuring municipal industrial 2. Identify staff to be 2. Year 1 2. How many Town staff facilities are meeting requirements trained need to be trained? of NPDES industrial permit(s) 3. BMP #35 3. BMP #35 3. BMP #35 #45 Oil Recycling Recycle oil used for vehicle and 1. Number of gallons of 1. Annually 1. Number of gallons of equipment needs oil recycled oil recycled? DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 35 Table 21: Pollution Prevention and Good Housekeeping BMPs Permit G.2.d: 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 Implementation Annual Reporting Metric #46 Street Sweeping Develop schedule for routine street 1. Develop map with 1. Year 1 1. Completed sweeping of Town maintained Town maintained streets streets which have curb and gutter with curb and gutter 2. Develop schedule and 2. Year 2 2. Has schedule and systems routes for routine street routes been established? sweeping 3. Implement routine 3. Year 3 3. How many miles of street sweeping streets have been swept? #47 Leaf Collection Periodic collection of leaves from 1. Develop contract for 1. Year 1 1. Volume of leaves residential and public areas to annual leaf collection by collected? reduce pollutants and clogging of a third party storm system inlets DRAFT NCS000559 SWMP Town of Clayton August 2022 Page 36