NCS000545_Draft SWMP_20221118

City of Creedmoor, North
Carolina
Comprehensive Stormwater
Management Plan Update
In Support of the City's
NPDES Phase II MS4 Permit
No. NCSOOO545
Adopted April 5th, 2022
P]

CITY OF CREEDMOOR
P.O. Box 765
111 MASONIC STREET
CREEDMOOR, NC 27522
W W W.CITYOFCREEDMOOR.ORG
[phone]
RESOLUTION 2022 - R - 02
MAYOR
ROBERT V. WHEELER
CITYMANAGER
GERALD C. SMITH SR.
KECHIA BRUSTMEYER-BROWN
GEORGANA KICINSKI
ED MIMS
ROBERT WAY
EMMA ALBRIGHT
Resolution adopting the Stormwater Management Plan Update 2022
WHEREAS, the City of Creedmoor through its National Pollutant Discharge Elimination
System (NPDES) permit is authorized to discharge stormwater from its Phase II
MunicipalSeparate Storm Sewer System (MS4), permit number NCS000545, located
within the corporate limits to receiving water of the Sate, Holman Creek, Beaverdam
Creek, Cedar Creek, Robertson Creek, and Ledge Creek, within the Neuse River Basin;
and
WHEREAS, Section 402(p) of the Federal Clean Water Act requires NPDES permits for
stormwater discharge from MS4; and
WHEREAS, the Department of Environmental Quality (DEQ) Division of Energy,
Mineral, and Land Resources is the agency that issues and oversees the NPDES permits
in North Carolina; and
WHEREAS, the City of Creedmoor's is working under its second NPDES permit which
became effective on February 1, 2018; and
WHEREAS, the NPDES permit is a perpetual permit on a five year permit renewal cycle;
and
WHEREAS, within the NPDES permit, Part I -Permit Coverage, the City of Creedmoor is
required to have a Stormwater Plan; and
WHEREAS, the permit requires the City of Creedmoor to implement the Stormwater Plan; and
WHEREAS, the City of Creedmoor has increased efforts to implement the six minimum measures
as required from the MS4 permit and included in the Stormwater Plan; and
WHEREAS, to better reflect these effort the Community Development Department with Raftelis
Financial Consultants Inc., in 2020, start work on updating the Stormwater Management Plan; and
WHEREAS, the Planning Board at the February 10, 2022 meeting recommended adoption of the
Stormwater Management Plan update to the Board of Commissioners: and

WHEREAS, the Board of Commissioners at the March 1, 2022 meeting moved to open a 35-day
public comment period for the Stormwater Management Plan update, and set a public hearing on
adoption of the Stormwater Management Plan for the April 5th, 2022 Board of Commissioners
meeting; and
NOW THEREFORE BE IT RESOLVED by the City of Creedmoor Board of Commissioners
that they do hereby:
1. Accepts the recommendation of the Planning Board for adoption of the Stormwater
Management Plan
2. Adopt the Stormwater Management Plan update as presented.
Adopted this the 51h day of April, 2022
64
ATTEST:
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Robert Wheeler, Mayor
d4i� 46S-r--
arbara Rouse, City Clerk
April 5th, 2022 Page 2

Table of Contents
1 INTRODUCTION......................................................................................................6
2 BACKGROUND INFORMATION.............................................................................8
2.1 Population Served................................................................................................
8
2.2 Growth Rate.........................................................................................................
8
2.3 Jurisdictional & MS4 Service Areas.............................................................8
2.4 MS4 Conveyance System.....................................................................................9
2.5 Land Use Composition Estimates.......................................................................10
2.6 Estimation Methodology..................................................................................11
2.7 TMDL Identification........................................................................................11
3 RECEIVING STREAMS..........................................................................................12
4 EXISTING WATER QUALITY PROGRAMS.........................................................13
4.1 Local Programs..................................................................................................13
4.2 State Programs...................................................................................................13
5 PERMITTING INFORMATION...............................................................................13
5.1 Organizational Chart..........................................................................................13
5.2 Responsible Party Contact Person......................................................................14
5.3 Signing Official..................................................................................................14
5.4 Duly Authorized Representative.....................................................................14
6 STORMWATER MANAGEMENT PROGRAM......................................................14
6.1 Public Education & Outreach on Storm Water Impacts......................................14
6.1.1 Target Pollutants and Stressors....................................................................15
6.1.2 Target Audiences........................................................................................15
6.1.3 Public Outreach and Education Program Implementation ............................15
6.1.4 Program Assessment...................................................................................17
Table 2 Best Management Practice for Public Education & Outreach ......................17
6.2 Public Involvement & Participation....................................................................19
6.2.1 Public Meeting............................................................................................19
6.2.2 Public Involvement Program Implementation..............................................19
[3]

6.2.3
Program Assessment...................................................................................21
Table 3
Best Management Practice for Public Involvement & Participation .............21
6.3 Illicit Discharge Detection & Elimination...........................................................23
6.3.1
IDDE Ordinance.........................................................................................24
6.3.2
Stormwater System Map.............................................................................24
6.3.3
Illicit Discharge Detection and Elimination Program...................................24
6.3.4
Employee Training......................................................................................26
6.3.5
Public Education and Outreach....................................................................26
6.3.6
Program Assessment...................................................................................26
Table 4
Best Management Practice for Illicit Discharge Detection & Elimination........
.......................................................................................................... 26 &
27
6.4 Construction Site Stormwater/Runoff Control....................................................29
6.5 Post Construction Stormwater Management- New Development and
Redevelopment.........................................................................................................
31
6.5.1
Post Construction Legal Authority..............................................................31
6.5.2
Stormwater Control Measures.....................................................................
32
6.5.3
Stormwater Permit Plan Review..................................................................32
6.5.4
SCM Operation and Maintenance Program.................................................33
6.5.5
Program Assessment...................................................................................
33
Table 5
Best Management Practice for Post Construction Stormwater Management
....
.......................................................................................................... 33 &
34
6.6 Pollution Prevention/Good Housekeeping for Municipal Operations ..................36
6.6.1 Inventory of Municipal Facilities and Operations........................................36
6.6.2 Operations and Maintenance Program at Municipal Facilities .....................37
6.6.3 Street Sweeping Operations.........................................................................38
6.6.4 Municipal Owned Stormwater Control Measures and MS4 System .............38
6.6.5 Employee Staff Training.............................................................................39
6.6.6 Vehicle and Equipment Cleaning Operations..............................................39
6.6.7 Program Assessment...................................................................................40
Table 6 Best Management Practice for Pollution Prevention/ Good Housekeeping.......
.......................................................................................................... 40 & 41
[4]

Acronym List
Abbreviation
Definition
AICP
American Institute of Certified Planners
BMP
Best Management Practice
CAMA
Coastal Area Management Act
CFR
Code of Federal Regulations
CWEP
Clean Water Education Partnership
CZO
Certified Zoning Official
DEMLR
Division of Energy, Mineral, and Land Resources
EMC
Environmental Management Commission
EPA
Environmental Protection Agency
ETJ
Extra Territorial Jurisdiction
GIS
Geographic Information System
IDDE
Illicit Discharge Detection and Elimination
I&M
Inspection & Maintenance
LID
Low Impact Development
MS4
Municipal Separate Storm Sewer System
NCAC
North Carolina Administrative Code
NCDEQ
North Carolina Department of Environmental Quality
NOV
Notice of Violation
NPDES
National Pollutant Discharge Elimination System
NSW
Nutrient Sensitive Water
SCM
Stormwater Control Measure
SL
Session Law
SNAP
Stormwater Nitrogen and Phosphorus Tool
SWMP
Stormwater Management Plan
SWPPP
Stormwater Pollution Prevention Plan
TMDL
Total Maximum Daily Load
[51

1 INTRODUCTION
On February 1, 2018, the City of Creedmoor (City) received their second National
Pollutant Discharge Elimination System (NPDES) permit (Permit No. NCS000545) from
the State of North Carolina Department of Environmental Quality (NCDEQ), Division of
Energy, Mineral, and Land Resources (DEMLR), authorizing them to discharge stormwater
from the City's municipal separate storm sewer system (MS4) located within the City's
corporate limits, to receiving waters of the State including Holman Creek, Beaverdam
Creek, Cedar Creek, Robertson Creek and Ledge Creek within the Neuse River Basin.
These discharges must be in accordance with the discharge limitations, monitoring
requirements, and other permit conditions including the development of this Stormwater
Management Plan (SWMP). This permit and plan are effective until February 1, 2023.
This SWMP is required by Part I, paragraphs A and G of the City's NPDES MS4 permit.
The objective of the SWMP is to establish how the permit requirements are implemented to
achieve permit compliance. The SWMP plan details the program elements to be
implemented under the permit program and includes: the specific best management
practices (BMPs) that are intended to fulfill the permit requirements; frequency of each
BMP; measurable program goals; implementation schedules; and responsible positions.
The City's Department of Community Development is the primary agency responsible for
managing the City's NPDES MS4 permit, the MS4 system and the SWMP.
Implementation of the requirements within the permit and SWMP activities are coordinated
with the Department of Public Works and other applicable City departments as necessary.
Funding for the BMPs specified in the SWMP is provided by local stormwater utility fees,
except where noted.
The SWMP includes the following core NPDES MS4 permit programs:
1. Public Education and Outreach Program — This program provides the general public and
businesses with information on general water quality, pollution prevention, and reporting
problems, as well as specialized information on various activities that have the potential to
[61

cause pollution and harm water quality. This information is delivered through a wide range
of methods including print, web, radio, social media, presentations, and public events.
2. Public Involvement and Participation Program — This program provides the general
public and businesses the opportunity to participate in various programs within the City's
SWMP. Litter cleanup events and the Pharmaceutical Drug Disposal Program are available
as public volunteer opportunities.
3. Illicit Discharge Detection and Elimination Program — This program is designed to
protect water quality by detecting and eliminating pollution sources such as improper
sewage or wastewater connections, illegal discharges of hazardous materials, other
chemicals and litter. As part of this program, the City enforces the "City of Creedmoor
Watershed Protection Ordinance," (Ord. 2018-0-09, ZTA-2018-05) which defines illicit
discharges and provides enforcement measures if illicit discharges are discovered. The City
is mapping its MS4 system to inspect for and track illicit discharges more efficiently. The
City relies on regular inspections of the MS4 system and reports from the public to assist in
identifying and eliminating these sources of pollution.
4. Construction Site Stormwater Runoff Control Program — This program is designed to
control sediments and other pollutants from construction sites. The NCDEQ Division of
Land Resources Erosion and Sediment Control Program effectively meets the
requirements of the Construction Site Runoff Controls in the City of Creedmoor by
permitting and controlling development activities disturbing one or more acres of
land surface and those activities less than one acre that are part of a larger common plan
of development.
5. Post -Construction Stormwater Management Program — This program is designed to
control the discharge of pollutants in stormwater runoff from new development and
applicable redevelopment projects. As part of this program, the City enforces the "City of
Creedmoor Watershed Protection Ordinance," which requires structural stormwater
controls for new development and applicable redevelopment projects as defined by current
State law. The program involves review and approval of project plans as well as site
[7]

inspections and maintenance activities to ensure that treatment practices are properly
operated and maintained.
6. Pollution Prevention/Good Housekeeping Program — This program focuses on ensuring
that City facilities and field operations are managed in a way that minimizes stormwater
pollutant discharges. Stormwater Pollution Prevention Plans and Spill Response Plans are
maintained for applicable facilities that conduct activities with the potential for stormwater
pollutant discharges. The City conducts inspections and training sessions at these facilities
to ensure that requirements are being met. Good housekeeping measures such as street
sweeping and off -site car washing have been implemented to reduce pollution.
2 BACKGROUND INFORMATION
2.1 Population Served
The City serves a current population of approximately 4,800 people. This is the
population based on information from the 2020 census. This data is located at
https://www2.census.goy/programs-surveys/decennial/2020/data/0I -Redistricting
PL_94-171/. Previous years of population data were found on the North Carolina Office of
State Budget and Management website
(https://files.nc.gov/ncosbm/demog/muniestbymuni_2019.html). This population does not
have seasonal variability.
2.2 Growth Rate
The following table (Table 1) provides historic estimated population data for the City from
the North Carolina Office of State Budget and Management website. According to this
information, the population growth during the 9-year time period shown was 14%, or 1.5%
per year (compounding).
YEAR
POPULATION
2020
4,866
2019
4,703
2010
4,124
Table 1. Population Data for the City of Creedmoor
181

2.3 Jurisdictional & MS4 Service Areas
Figure 1 shows City's official map, which includes the City's jurisdictional boundary
as well as the City's Extraterritorial Jurisdictional (ETJ) Areas. The size of these
area's as well as the size of the Land Area served by the MS4 are described in further
detail below. The MS4 area is the City's jurisdictional boundary (corporate limits).
._ I
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Figure 1. Official City Map for the City of Creedmoor
0
Official City Map
City of Creedmoor
NORTH CAROLINA
H
XA ooten
I. Land Area of Primary Corporate Limits 5.55 square miles
2. Land Area of Secondary (Satellite) Corporate 0.12 square miles
Limits
3• Estimated Land Area served by MS4 5.67 square miles
2.4 MS4 Conveyance System
The City's MS4 Conveyance system is currently being mapped by The Wooten
Company with an estimated completion date of December 2021. This system is
comprised of stormwater drains, concrete structures, culvert pipes, grass swales, and
[91

associated outfalls. The system also has several privately -owned stormwater control
measures (SCM) and one SCM owned and operated by the City, at the Creedmoor
Community Center, built for the purposes of post -construction stormwater
management, which were constructed to meet requirements of the NPDES permit and
this SWMP. Upon completion of the map, this report will be updated to include a
copy.
1
4.
— A
"
4
a
ktik�*
.
N
Figure 2. MS4 Outfalls and Receiving Waters map for the City of Creedmoor
2.5 Land Use Composition Estimates
Figure 2 is a zoning map of the City, which shows the various land uses within the City.
The estimated size of these areas is provided in the further detail below.
1. Residential Land Use:
3.16
square miles
30.62%
2. Commercial Land Use:
0.68
square miles
6.59%
3. Industrial Land Use:
0.33
square miles
3.20%
4. Open Space:
6.15
square miles
59.59%
[10]

OFFICIAL
ZONING MAP
City Of C—d—
North Carolina
- Wooten
Figure 3. Zoning Map for the City of Creedmoor
2.6 Estimation Methodology
GIS mapping information was used to determine the area and ratio of land uses. Simple
land area calculations were completed using the following logic:
Residential Areas: Areas currently zoned for Residential Use
Commercial Areas: Areas currently zoned for Commercial Use
Industrial Areas: Areas currently zoned for Industrial Use
Open Space: Areas currently zoned for Open Space
MS4 Service Area: Area of the City's Corporate Limits
2.7 TMDL Identification
The City is currently not subject to any TMDL nutrient reduction requirements. However,
the City does provide nitrogen and phosphorus reduction as part of the Falls Lake Nutrient
Management Strategy (SL 2005-190; Falls Lake Rules; S981) The goal of these strategies
[11]

is to reduce concentrations of chlorophyll -a concentrations in the Lake.
3 RECEIVING STREAMS
Stormwater from the City is discharged to following designated waters of the State (as
shown on Figure 3):
• Holman Creek
• Beaverdam Creek
• Cedar Creek
• Robertson Creek
• Ledge Creek
• Whitaker Branch
Robertson Creek���
Holman Creek
S� Cedar Creek
Beaverdam Creek
Ledge Creek
Whitaker Branch hO
I
� sau�:Es: scs,H
N
A 0 0.375 0.75 1.5 225 3
Miles
Figure 4. City of Creedmoor Designated Waters of the State
[12]

4 EXISTING WATER QUALITY PROGRAMS
4.1 Local Programs
Local Nutrient Sensitive Waters Strategy: YES
Local Water Supply Watershed Program: YES
Delegated Erosion and Sediment Control Program: NO
CAMA Land Use Plan: NO
4.2 State Programs
Erosion and Sediment Control Program: YES
5 PERMITTING INFORMATION
5.1 Organizational Chart
Figure 4 below is the most current Organizational Chart for City departments and
staff that are involved the stormwater program implementation.
Figure 5. City of Creedmoor Stormwater Organization Chart
[131

5.2 Responsible Party Contact Person
Contact:
Michael Frangos, AICP, CZO
Title:
Stormwater Administrator
Street Address:
111 Masonic Street
PO Box:
PO Box 765
City:
Creedmoor
State:
North Carolina
Zip Code:
27522
Telephone:
919 764-1016
�919)528-3052
Fax Number:
E-mail Address:
mfran os e,cityofcreedmoor.org
5.3 Signing Official
Contact:
Michael Frangos, AICP, CZO
Title:
Stormwater Administrator
Street Address:
111 Masonic Street
PO Box:
PO Box 765
City:
Creedmoor
State:
North Carolina
Zip Code:
27522
Telephone:
9 764-1016
Fax Number:
P9)528-3052
E-mail Address:
mfrangoskcityofcreedmoor.org
5.4 Duly Authorized Representative
Under Article 19, Section 2, Subsection 19.14-1 of the Creedmoor Development Ordinance
(Appendix A), the City Board of Commissioners shall designate a Stormwater
Administrator. Michael Frangos, AICP, CZO, Community Development Director was duly
appointed as the Stormwater Administrator for the City on November 20th, 2018, by the
City Board of Commissioners. This plan will be updated upon any changes to this
appointment.
6 STORMWATER MANAGEMENT PROGRAM
6.1 Public Education & Outreach on Storm Water Impacts
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the City will implement a
public education program to distribute educational materials to the community or conduct
equivalent outreach activities about the impacts of storm water discharges on water bodies
and the steps that the public can take to reduce pollutants in storm water runoff.
[14]

The following sub -sections explain:
• Target audience and pollution sources;
• Program implementation; and
• Program assessment
6.1.1 Target Pollutants and Stressors
The City has defined the target pollutants and stressors that it will address as part of
its Public Education and Outreach Program as Nitrogen and Phosphorus. These
nutrients in stormwater contribute to the exceedance of chlorophyll -a in the Falls
Lake Watershed. Non -point sources of these pollutants include yard maintenance
and debris, fertilizers and animal waste.
6.1.2 Target Audiences
The City has identified all residents within the City limits, pet owners, and school
children as the target audience of their Public Education and Outreach Program.
City residents were selected because they are most likely to apply fertilizer on their
property, often without the knowledge or training necessary to apply fertilizers
properly. Without this knowledge or training, excessive amounts of Nitrogen and
Phosphorus can enter the MS4 system. Pet owners were selected because animal
waste can also be a contributor of Nitrogen and Phosphorus if not disposed of
properly. School Children were selected because educating them about stormwater
practices instills a sense of responsibility and environmental stewardship which
they can bring home to encourage positive behavior in their families.
6.1.3 Public Outreach and Education Program Implementation
The City's Stormwater Public Education and Outreach Program will provide water
quality and pollution prevention messages to educate residents about the ways they
can help protect water quality and get involved to help reduce stormwater pollution.
The program will provide these messages through the following ways:
An internet web site. The City's Stormwater Website
(http s: //www. cityo fcreedmo or. ora/departments-and-
services/community-development/plannin -zg oning/stormwater-
proaram/what-you-can-do) will contain information regarding
[151

the City's NPDES permit, the stormwater hotline /helpline(as
described in detail below) and links to public education materials
(as described in detail below) and to additional information at the
Clean Water Education Partnership (CWEP).
2. Public education materials. A wide variety of print media and
promotional materials about water quality and pollution
prevention will be maintained and provided to the public. This
includes brochures and fact sheets. Print media and promotional
products will be distributed during public events, presentations,
and/or through direct mail.
3. Public outreach events. The City's Community Development
Office has previously presented a stormwater education booth at
the annual Public Works Day event and City of Creedmoor
Music Festival, distributed public education materials as
described above, displayed a slide show regarding stormwater,
and conducted demonstrations regarding impacts to stormwater
from erosion. The City will continue to conduct public outreach
events, these events may stay the same or change based upon the
results of the annual program evaluation.
4. Mass media and social media. The City will continue to utilize
several media sources to educate the public regarding
stormwater. The City will maintain a contract with CWEP to
produce and distribute an environmental education media
campaign on local television stations. The City will publish one
or more educational articles per year in the City's newsletter,
Creedmoor Happenings. The City will post one or more articles
per year on their Facebook page.
5. A stormwater hotline/helpline. The City will continue to
maintain a stormwater hotline/helpline and advertise it on the
City's stormwater website. The City will also advertise the
hotline/helpline on stormwater informational posters which will
be displayed throughout the City. The City will maintain a
[161

tracker to track complaints and outcomes. Calls to any City
office regarding stormwater will be routed to the Community
Development office, and Community Development employees
will provide stormwater education to citizens during the course
of these calls.
6. School Presentations. The City will continue to maintain a
contract with CWEP to conduct an annual stormwater education
lesson at South Granville High School.
7. Pet Waste Cleanup Stations. The City has installed several pet
waste cleanup stations on City owned properties and along the
Cross City Trail to educate the public of the importance of
cleaning up pet waste in maintaining a healthy environment and
waterways. The City will continue to maintain their pet waste
stations.
8. LED Digital Sign. Next to the City of Creedmoor Community
Center an LED digital sign allows stormwater messages to be
displayed. The City will continue to post stormwater messages.
6.1.4 Program Assessment
The overall success of the Public Education and Outreach Program is evaluated
through the successful implementation of the components of the program and
reported with each NPDES MS4 annual report. This plan will be updated should the
evaluation find that some measures have not met measurable goals. Additional
information regarding program assessment can be found in Table 2 below.
[171

Table 2: Public Outreach and Education BMPs.
BMP
Measurable Goals
Schedule for Implementation
Reporting Metric
Goals and
Define the goals and objectives of the Public
Throughout the permit period, with
Goals and objectives will be evaluated
7a.tablish
Objectives
Education and Outreach program based upon
annual evaluation and updates if
annually and updated as needed
community wide issues
necessary
b. Describe target pollutants
Identify the target pollutant and target pollutant
Throughout the permit period, with
Targeted pollutants will be evaluated
sources the permittee's public education program is
annual evaluation and updates if
annually and updated as needed.
designed to address and why they are an issue.
necessary
c. Describe targeted
Identify the target audiences likely to have
Throughout the permit period, with
Target audiences will be evaluated
audiences
significant stormwater
annual evaluation and updates if
annually and updated as needed.
impacts and why they were selected.
necessary
d. Describe residential and
Identify and describe residential and
Throughout the permit period, with
Residential and industrial/commercial
industrial/commercial issues
industrial/commercial water quality issues such as
annual evaluation and updates if
issues will be evaluated annually and
pollutants, sources of pollutants, and impacts on
necessary
updated as needed.
water quality.
e. Informational Website
Promote and maintain Internet web site.
Throughout the permit period, with
The number of unique and total page visits
annual evaluation and updates if
will be recorded annually
necessary
f. Distribute Public Education
Develop stormwater educational material to
Throughout the permit period, with
The number of educational materials that
materials to target audiences
appropriate target groups as likely to have a
annual evaluation and updates if
were distributed to target audiences will
significant stormwater impact.
necessary
be recorded annually
g. Maintain hotline/helpline
Maintain and promote a stormwater hotline/helpline
Throughout the permit period, with
Number of calls to hotline/helpline to
for the purpose of public education and outreach
annual evaluation and updates if
report water quality issues will be
necessary
recorded annually. Number of
mechanisms utilized to share
hotline/helpline (e.g., brochures,
promotional items) will be recorded
annually
h. Implement a Public
Establish and implement a public education and
Throughout the permit period, with
Extent of exposure will be recorded
Education and Outreach
outreach program through a combination of
annual evaluation and updates if
annually for each outreach and education
Program
approaches designed to reach the target audiences.
necessary
strategy
For each media, event or activity estimate and record
the extent of exposure.
[18]

6.2 Public Involvement & Participation
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the City will implement a
public involvement and participation program which must, at a minimum, comply with
State and local public notice requirements.
The following sub -sections explain:
• The public meeting;
• Program implementation; and
• Program assessment.
6.2.1 Public Meeting
The City held several Board of Commissioners meetings during the first permit
term, which are open to public citizens, regarding their stormwater program on May
22, 2012 (discussion regarding potential stormwater utility rates), June 26, 2013
(discussion regarding the Stormwater Utility Ordinance and Stormwater Program
for New Development), July 24, 2012 (discussion regarding Interlocal Agreement
for Stormwater), and August 28, 2012 (discussion regarding Stormwater Plan
Review). The City will bring any update to this plan to the Planning Board and
Board of Commissioners for Board approval and public comment.
6.2.2 Public Involvement Program Implementation
The City's Stormwater Public Involvement Program provides residents
opportunities to protect water quality and get involved to help reduce stormwater
pollution. The program provides these opportunities through the following ways:
1. Volunteer Opportunities. The City will provide volunteers the
opportunity to help educate their community about stormwater
pollution through several events.
a. Litter Sweep. The City collaborates with local
volunteer groups such as Boy Scouts and local
business to clean up litter from local waterways and
parks. The City also has annual litter cleanups along
roadways in conjunction with the North Carolina
[19]

Department of Transportation's statewide cleanup.
Local citizens are invited to participate in these
events, which are advertised on the City website.
b. Operation Medicine Drop. The City hosts a twice -
annual collection of unused or expired prescription or
over-the-counter medications to keep them out of
landfills and from polluting local waterways. A
Pharmaceutical drug disposal box is also located in
City Hall for year round anonymous disposal of
prescription medication.
2. An internet website. The City's will continue to maintain a "What
You Can Do" page and link to a brochure educating citizens on what
they can do to protect stormwater on their website.
(http s: //www. cityo fcreedmo or. org/departments-and-
services/community-development/plannin -zg oning/stormwater-
pro gram/what-you-can-do)
3. Community Outreach. The City will continue to collaborate with the
community during the development of City land conservation
projects including conservation easements, greenway trails, other
connections to open space in the City. These projects are supported
by the Clean Water Management Trust Fund, the Triangle Land
Conservancy, the North American Land Trust, and the Upper Neuse
Clean Water Initiative.
4. A stormwater hotline/helpline. The City will continue to maintain a
stormwater hotline/helpline which is advertised on the City's
stormwater website. The City will also advertise the hotline/helpline
on stormwater informational posters which will be displayed
throughout the City. The City will maintain a tracker to track
complaints and outcomes. Calls to any City office regarding
stormwater will be routed to the Community Development office,
and Community Development employees will provide stormwater
education to citizens during the course of these calls.
[20]

6.2.3 Program Assessment
The overall success of the Public Involvement and Participation Program is
evaluated through the successful implementation of the components of the program
and reported with each NPDES MS4 annual report. Additional information
regarding program assessment can be found in Table 3 below.
[21 ]

Table 3: Public Involvement and Participation BMPs
BMP
Measurable Goals
Schedule for Implementation
I Reporting Metric
a. Allow the public an opportunity to review
Conduct at least one public meeting during
One public meeting will be held during this
Meeting minutes and attendees from
and comment on the Stormwater Program
the permit period to allow the public an
permit period
the public meeting will be recorded
opportunity to review and comment on the
Stormwater Program.
b. Establish and implement a volunteer
Organize and promote volunteer
Evaluation of the program will be conducted
The number of events and number of
community involvement program
opportunities to promote ongoing citizen
annually with updates to the program if
volunteers will be recorded annually
participation in the stormwater program
necessary.
c. Mechanism for Public Involvement
Establish a mechanism for public
One public meeting will be held during this
Meeting minutes and attendees from
involvement
permit period. Evaluation of the program
the public meeting will be recorded.
will be conducted annually with updates to
The mechanism for public
the program if necessary.
involvement will be evaluated
annually and updated as needed.
d. Maintain hotline/helpline
Maintain and promote a stormwater
Evaluation of the program will be conducted
Number of calls to helpline/hotline to
hotline/helpline for the purpose of public
annually with updates to the program if
report water quality issues will be
involvement
necessary.
recorded annually.
Number of mechanisms utilized to
share hotline/helpline (e.g., brochures,
promotional items) will be recorded
annually
[22]

6.3 Illicit Discharge Detection & Elimination
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the City must:
a) Develop, implement and enforce a program to detect and eliminate illicit
discharges (as defined at Sec. 122.26 (b)(2)) into our MS4;
b) Develop a storm sewer system map, showing the location of all outfalls and the
names and location of all waters of the United States that receive discharges
from those outfalls;
c) Effectively prohibit, through ordinance, or other regulatory mechanism, non -
storm water discharges into our storm sewer system and implement appropriate
enforcement procedures and actions;
d) Develop and implement a plan to detect and address non -storm water discharges
and illegal dumping into our system;
e) Inform public employees, businesses, and the general public of hazards
associated with illegal discharges and improper disposal of waste; and
0 Address the following categories of non -storm water discharges or flows (i.e.,
illicit discharges) if we identify them as significant contributors of pollutants
into our MS4:
1) water line flushing,
2) landscape irrigation (including lawn watering & irrigation water)
3) diverted stream flows,
4) rising ground waters,
5) uncontaminated ground water infiltration (as defined at 40 CFR
35.2005(20)),
6) uncontaminated pumped ground water,
7) discharges from potable water sources,
8) foundation drains,
9) air conditioning condensation,
10) springs,
11) water from crawl space pumps,
12) footing drains,
13) individual residential car washing,
[23]

14) flows from riparian habitats and wetlands,
15) de -chlorinated swimming pool discharges, and
16) street wash water
17) Exceptions include: discharges or flows from fire -fighting activities
(excluded from the effective prohibition against non -storm water and
will only be addressed where they are identified as significant sources
of pollutants to waters ofthe United States).
The following sub -sections explain:
• The BMPs intended to meet program requirements;
• Integral components of the IDDE program;
• Education strategy; and
• Program Assessment.
6.3.1 IDDE Ordinance
The City adopted its Watershed Protection Ordinance (Article 19) on June 18, 2012
and subsequently amended the Ordinance on November 20, 2018 per Ord. 2018-0-
09, ZTA-2018-05. Section 6 of this ordinance specifically addresses Illicit
Discharges. This ordinance is enforced as part of the NPDES MS4 permit and
SWMP. Detailed administration, remediation and enforcement procedures are
maintained for the ordinance.
6.3.2 Stormwater System Map
The City has contracted with The Wooten Company to produce a map of the City's
MS4 stormwater system. The City will maintain and update the inventory of its
MS4 system using Geographic Information Systems (GIS) which includes data for
major outfalls and sub -basins. New stormwater infrastructure will be entered into
the GIS inventory for new development projects. Inventory data will be stored and
maintained digitally. Hard copy maps showing major outfalls and receiving
streams can be produced as needed. This report will be updated with a copy of the
map once it has been completed
6.3.3 Illicit Discharge Detection and Elimination Program
The City will continue to implement their IDDE program in the following ways:
[24]

1. Outfall Inspections/Inventory — Monitoring of dry weather flows
will be conducted by the City's Public Works and Community
Development staff during routine maintenance and inspection
site visits. If dry weather flows are observed; sensory cues are
used and samples are collected to determine if the flow is a
pollution source. Immediate follow-up field screening activities
are initiated to identify and eliminate pollution sources. Notice of
Violation (NOVs) are sent to the property owner if illicit
discharges are discovered during the inspection process. The City
has created a stormwater inspection tracker to track all
stormwater outfall inspections, outcomes and resolutions (if any).
The City has also created an IDDE tracker to track any IDDE
NOVs and resolutions.
2. Water Quality Monitoring — Water quality monitoring will be
conducted to identify illicit connections and discharges,
determine general water quality conditions and target water
quality problem areas for additional follow-up actions. Water
quality monitoring reports will be produced annually to
document findings of the sampling.
3. A stormwater hotline/helpline. The City will continue to
maintain a stormwater hotline/helpline which is advertised on the
City's stormwater website. The City will also advertise the
hotline/helpline on stormwater informational posters which will
be displayed throughout the City. The City has developed a
tracker to track complaints and outcomes. Calls to any City
office regarding stormwater will be routed to the Community
Development office, and Community Development employees
will provide stormwater education to citizens during the course
of these calls.
[251

6.3.4 Employee Training
Training about illicit discharges will continue to be provided to a variety of City
employees, including Public Works and Stormwater Administration staff, and
typically includes:
• How to recognize common illicit discharges;
• Their impact on surface water quality;
• Why protecting surface water is important for the community;
• Pollution prevention practices;
• How to report illicit discharges; and
• How these reports are investigated and enforced.
The City will continue to update information on employee training including names
of courses, dates, and certifications.
6.3.5 Public Education and Outreach
The City will continue to maintain a public education and outreach program to
inform businesses and the general public about illicit discharges and improper waste
disposal and how they impact the environment. This education and outreach
program includes instructions regarding the proper method for reporting illicit
discharges on the City's website. Public education and outreach items for the IDDE
Program are included as a component of the Public Education and Outreach
Program described in Section 6.1 above.
6.3.6 Program Assessment
The overall success of the IDDE Program is evaluated through the successful
implementation of the components of the program and reported with each NPDES
MS4 annual report. Additional information regarding program assessment can be
found in Table 4 below.
[261

Table 4: Illicit Discharge and Detection Elimination BMPs
BMP
Measurable Goals
Schedule for Implementation
Reporting Metric
a. Maintain an Illicit Discharge Detection
Develop and implement an Illicit Discharge
The program has been implemented. The
The IDDE program will be evaluated
and Elimination Program
Detection and Elimination Program
program will be maintained throughout the
annually and updated as needed
including provisions for program assessment
permit period, with annual evaluation and
and evaluation.
updates if necessary.
b. Maintain appropriate legal authorities
Maintain adequate ordinances or other legal
The ordinance has been approved and
The effectiveness of the ordinance will
authorities to prohibit illicit discharges and
implemented. Annual evaluation and updates
be evaluated annually and updated as
enforce the approved Illicit Discharge
will be made throughout the permit period if
needed
Detection and Elimination Program.
needed.
c. Develop and maintain a Storm Sewer
Map identifying major outfalls and
The Storm Sewer System map is currently
The system map will be evaluated
System Map of Major Outfalls
stormwater drainage system components. At
being produced with ongoing updates being
annually and updated as needed
a minimum, components include major
made as needed.
outfalls and receiving streams. Establish
procedures to continue to identify, locate,
and update the map of the drainage system.
d. Inspection/detection, tracking and
Establish written procedures for detecting
The program has been implemented. The
Observed discharges, results of
elimination program to detect illicit
and tracing the sources of illicit discharges
program will be maintained throughout the
investigation, follow up, and case
discharges including dry weather flows
and for removing the sources or reporting the
permit period, with annual evaluation and
closure dates will be reported annually
sources to the State to be properly permitted.
updates if necessary.
Establish and implement tracking of
investigations.
e. Provide employee training
Implement training program for appropriate
Employee training will be conducted
Document and maintain records of the
municipal staff, who, as part of their normal
throughout the permit period, with annual
training provided and the staff trained.
job responsibilities, may come into contact
evaluation and updates to the training
with or otherwise observe an illicit discharge
program if necessary.
or illicit connection to the storm sewer
system. The training program shall identify
appropriate staff, the schedule for conducting
the training and the proper procedures for
reporting and responding to an illicit
discharge or connection. Follow-up training
shall be provided as needed to address
changes in procedures, techniques, or
staffing.
[27]

Table 4: Illicit Discharge and Detection Elimination BMPs cont'd
BMP
Measurable Goals
Schedule for Implementation
Reporting Metric
f. Provide public education
Inform public employees, businesses, and
Public education will be conducted
Public Education materials will be
general public of hazards associated with
throughout the permit period, with annual
evaluated annually and updated as
illegal discharges and improper disposal of
evaluation and updates to the education
needed
waste.
program if necessary
g. Provide a public reporting mechanism
Promote, publicize, and facilitate a reporting
A public reporting hotline has been
Number of calls to hotline to report
mechanism for the public and staff to report
implemented. The hotline will remain the
illicit discharges will be recorded
illicit discharges and establish and
permit period, with annual evaluation and
annually
implement citizen request response
updates if necessary
procedures. Conduct reactive inspections in
Reports to the hotline and outcomes
response to complaints and follow-up
from those calls will be reported
inspections as needed to ensure that
annually
corrective measures have been implemented
by the responsible party to achieve and
maintain compliance.
h. Provide a mechanism to enforce the IDDE
The permittee shall implement a mechanism
The mechanism to enforce the IDDE
NOVs and enforcement actions will be
ordinance
to track the issuance of notices of violation
program has been implemented via
reported annually
and enforcement actions. This mechanism
ordinance. Enforcement will continue
shall include the ability to identify chronic
throughout the permit period, with annual
violators for initiation of actions to reduce
evaluation and updates if necessary
noncompliance.
[28]

6.4 Construction Site Storm water/Runoff Control
Pursuant to Federal Regulations 40 CFR Section 122.34(b) the City must develop,
implement, and enforce a program to reduce pollutants in any storm water runoff into our
MS4 from construction activities that result in a land disturbance of greater than or equal to
one acre. Reduction of storm water discharges from construction activity disturbing less
than one acre will be included in our program if that construction activity is part of a larger
common plan of development or sale that would disturb one acre or more. If the NPDES
permitting authority waives requirements for storm water discharges associated with small
construction activity in accordance with Sec. 122.26(b)(15)(i), we are not required to
develop, implement, and/or enforce a program to reduce pollutant discharges from such
sites. The program will include the development and implementation of, at a minimum:
a) An ordinance or other regulatory mechanism to require erosion and sediment
controls, as well as sanctions to ensure compliance, to the extent allowable
under State, Tribal, or local law;
b) Requirements for construction site operators to implement appropriate erosion
and sediment control best management practices;
c) Requirements for 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 impacts to water quality;
d) Procedures for receipt and consideration of information submitted by the public,
and
e) Procedures for site inspection and enforcement of control measures.
Pursuant to 40 CFR 122.35, an operator of a regulated small MS4 may share the
responsibility to implement the minimum control measures with other entities
provided:
a) The other entity, in fact, implements the control measure;
b) The particular control measure, or component thereof, is at least as stringent
as the corresponding NPDES permit requirement; and
[29]

c) The other entity agrees to implement the control measure on behalf of the
MS4.
Pursuant to State Requirements in Session Law 2006-246 Section 7 "to obtain a
Phase II National Pollutant Discharge Elimination System (NPDES) permit for storm -
water management, [the city] shall, to the extent authorized by law, develop,
implement, and enforce a stormwater management plan approved by the Commission
that satisfies the six minimum control measures required by Code 40 of Federal
Regulations § 122.34(b)(1 July 2003 Edition)." Regulated entities may propose using any
existing State or local program that relates to the minimum measures to meet, either in
whole or in part, the requirements of the minimum measures.
The NCDEQ Division of Land Resources Erosion and Sediment Control
Program effectively meets the requirements of the Construction Site Runoff Controls
in the City of Creedmoor by permitting and controlling development activities
disturbing one or more acres of land surface and those activities less than one acre that
are part of a larger common plan of development. This program is authorized under
the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North
Carolina Administrative Code. This program includes procedures for public input,
sanctions to ensure compliance, requirements for construction site operators to
implement appropriate erosion and sediment control practices, review of site plans
which incorporates consideration of potential water quality impacts, and procedures
for site inspection and enforcement of control measures. The NCGO 10000 permit
establishes requirements for 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 impacts to water quality.
[30]

6.5 Post Construction Stormwater Management- New Development
and Redevelopment
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the City must
develop, implement, and enforce a program to address storm water 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 discharge into our MS4. The program will ensure that
controls are in place that would prevent or minimize water quality impacts. The City
will at a minimum:
a) Develop and implement strategies which include a combination of structural
and/or non-structural best management practices (BMPs) appropriate for
our community;
b) Use an ordinance or other regulatory mechanism to address post -
construction runoff from new development and redevelopment projects to
the extent allowable under State, Tribal or local law; and
c) Ensure adequate long-term operation and maintenance of BMPs.
The following sub -sections explain:
• The BMPs intended to meet program requirements;
• Integral components of the program; and
• Program Assessment.
6.5.1 Post Construction Legal Authority
The City has adopted several mechanisms to meet the legal requirements of the
Post -Construction Stormwater Management Program including the Post -
construction Stormwater Runoff Controls for Development in the Falls
Watershed. The stormwater management and water quality protection
promulgated in Rule 15A NCAC 02B .0277 Stormwater Management for New
Development, and Rule 15A NCAC 02B .0278 Stormwater Management for
Existing Development effectively meets the Post -construction Stormwater
Runoff control requirements within the Falls Lake Water Supply.
[311

6.5.2 Stormwater Control Measures
BMP strategies for the City's Post -Construction Stormwater Management program
will consist mainly of structural stormwater control measures (SCMs) such as sand
filters, wet ponds, wetlands, and bioretention areas. SCMs should be designed in
accordance with the NC Department of Environmental Quality Stormwater
Design Manual (NCDEQ BMP Manual). SCMs will be required on projects that
have high density development and disturb more than one-half acre of land for
residential or recreational development that is not part of a larger common plan of
developer or sale or disturb more than 12,000 square feet of land for non-
residential/recreational developments that are not part of a larger common plan of
development or sale. In addition, SCMs must be designed to:
• Reduce Nitrogen and Phosphorus loads to not exceed 2.2 and 0.33 pounds per acre
per year, respectively;
Control and treat the runoff generated from all surfaces by one inch of rainfall;
• Control the peak flow from the 1-year — 24-hour storm event; and
• Convey the runoff from the 10-year storm event without surcharging the drainage
system.
The program will also require proper operation, maintenance, and inspection of
SCMs as discussed in Section 6.5.4 below.
6.5.3 Stormwater Permit Plan Review
For a stormwater permit to be reviewed and issued by the City of Creedmoor,
several documents must be submitted. The documentation required to apply for a
stormwater permit consists of:
• City Stormwater Permit Application;
• SNAP Tool (an interactive Excel spreadsheet that calculates nutrient reduction);
• Three (3) sets of plans;
• A copy of the operations and maintenance manual for the engineered SCM's
proposed;
• Application fee (as listed in the City's Fee and Rate Schedule)
[32]

All permit requirements will continue to be provided to developers on the City
webpage (https://www.cityofcreedmoor.or /g/departments-and-services/community-
development/plannin -zg oning/stonnwater-progxam/obtaining-stormwater-permits).
6.5.4 SCM Operation and Maintenance Program
The City will continue to require deed restrictions and protective covenants to
ensure that SCMs remain consistent with approved plans. Streams and buffer
boundaries will be required on all surveys and record plats. An operation and
maintenance agreement for SCMs will be required to be referenced on record plats
and recorded in deeds. In addition, a maintenance easement will be required to be
recorded to provide access to structural SCMs.
The City will also require an operation and maintenance agreement executed by the
responsible party (owner) of each SCM. As part of the program, the owner will be
required to:
• Conduct annual inspections of SCMs;
• Submit inspection reports to the City;
• Repair any deficiencies in the SCM found during the inspection process;
• Obtain and submit performance and maintenance security or bonds for each SCM
annually; and
• Maintain proper records documenting operation and maintenance activities.
Any owner that fails to submit the required documents and properly maintain their
SCM may be subject to an enforcement action by the City. The City will continue
to maintain electronic copies of all SCM plans, inspection reports, securities/ bonds
and enforcement actions.
6.5.5 Program Assessment
The overall success of the Post -Construction Stormwater Management Program is
evaluated through the successful implementation of the components of the program
and reported with each NPDES MS4 annual report. Additional information
regarding program assessment can be found in Table 5 below.
[331

Table 5: Post -Construction Stormwater Management Program BMPs
BMP
Measurable Goals
Schedule for Implementation
Reporting Metric
a. Establish a Post -Construction Stormwater
Develop and adopt by ordinance (or similar
The City's Watershed Development
The effectiveness of the ordinance
Management Program, including legal
regulatory mechanism) a program to address
ordinance has been developed, approved and
will be evaluated annually and
authorities
stormwater runoff from new development
implemented. Evaluation annually.
updated as needed.
and redevelopment. Implement and enforce
the program within 24 months of the permit
issue date. Annually review and
revise/update as necessary
b. Establish strategies which include BMPs
Develop strategies that include a
The stormwater management and water
The effectiveness of the Falls Rules
appropriate for the MS4
combination of structural and/or
quality protection promulgated in Rule 15A
will be evaluated annually and
nonstructural BMPs. Provide a mechanism to
NCAC 02B .0277 Stormwater Management
updates to the City's program made as
require long-term operation and maintenance
for New Development, and Rule 15A NCAC
needed
of structural BMPs. Require annual
02B .0278 Stormwater Management for
inspection reports of permitted structural
Existing Development effectively meets the
BMPs performed by a qualified professional
Post -Construction Stormwater Runoff
(i.e., someone trained and certified by NC
control requirements within the Falls Lake
State for BMP Inspection & Maintenance).
Water Supply.
c. Plan reviews
Conduct site plan reviews of all new
Plan reviews will be conducted throughout
The effectiveness of the plan reviews
development and redeveloped sites that
the permit period.
will be evaluated annually and
disturb greater than or equal to one acre and
updated as needed. The number of
discharge to the MS4 (including sites that
plans reviewed and approved will be
disturb less than one acre that are part of a
tracked annually.
larger common plan of development or sale).
d. Inventory of projects with post-
Maintain an inventory of projects with post-
Inventory has been completed, is updated
Number of new SCMs associated
construction structural stormwater control
construction structural stormwater control
continuously and evaluated annually.
with a project that have received a
measures
measures installed and implemented at new
Certificate of Occupancy.
development and redeveloped sites,
including both public and private sector sites
located within the permittee's jurisdiction
area that are covered by its post construction
ordinance requirements.
[34]

Table 5: Post -Construction Stormwater Management Program BMPs cont'd
BMP
Measurable Goals
Schedule for Implementation
Reporting Metric
e. Deed restrictions and protective covenants
Provide mechanisms such as deed
Mechanism is complete. Evaluate and
New deed restrictions or protective
restrictions or protective covenants to ensure
update annually as needed. Continuously
covenants are recorded annually.
development activities will remain consistent
ensure that deed restrictions and protective
with approved plans
covenants are recorded.
f. Long-term Operation and Maintenance of
Require an operation and maintenance plan
O&M requirements have been put in place
Track annual inspection reports,
structural SCMs
for the long-term operation SCMs.
through the City's Watershed Protection
security bonds, and any operation and
ordinance. Evaluate and update annually as
maintenance activities.
needed.
Ensure that O&M plans are required and
recorded throughout the permit term.
Evaluation conducted annually.
Ensure that annual inspections are performed
by a qualified professional. Evaluation
conducted annually.
g. Inspections
Conduct and document inspections of each
Inspections will be conducted throughout the
Track annual inspections and
project site covered under performance
permit term. The inspection program will be
maintain inspection records.
standards, at least one time during the permit
evaluated annually.
term.
h. Educational materials and training for
Make available through paper or electronic
Educational materials for developers can be
Education materials will be evaluated
developers
means, ordinances, post -construction
found on the City's website. Evaluation of
annually and updated as needed
requirements, design standards checklists,
these materials will be conducted annually.
and other materials appropriate for
developers.
i. Enforcement
Track the issuance of notices of violation and
This tracking mechanism has been
Number of NOVs and other
enforcement actions. This mechanism shall
implemented and will be evaluated annually.
enforcement actions reported
include the ability to identify chronic
annually. The effectiveness of the
violators for initiation of actions to reduce
enforcement mechanism will be
noncompliance.
evaluated annually.
[35]

6.6 Pollution Prevention/Good Housekeeping for Municipal
Operations
Pursuant to Federal Regulations 40 CFR Section 122.34 (b) the city will
develop and implement an operation and maintenance program that includes a training
component and has the ultimate goal of preventing or reducing pollutant runoff from
municipal operations. Using training materials that are available from EPA, the State of
North Carolina, or other organizations, our program will include employee training to
prevent and reduce stormwater pollution from activities such as park and open space
maintenance, fleet and building maintenance, new construction and land disturbances,
and storm water system maintenance.
The following sub -sections explain:
• The BMPs intended to meet program requirements;
• Integral components of the program;
• Employee education and training; and
• Program assessment.
6.6.1 Inventory of Municipal Facilities and Operations
The City provides an extensive network of municipal operations designed to serve
its citizens and keep vital infrastructure functioning properly. All parcels of land
owned or operated by the City are examined to determine whether they are included
in the Municipal Facilities Inventory within the Pollution Prevention/Good
Housekeeping Program. A Standard Administrative Procedure is followed when
evaluating parcels for this inventory. Once included in the inventory, facilities will
receive:
• Preparation and implementation of a Stormwater Pollution Prevention Plans
(SWPPP);
• Regular inspections; and
[36]

• Annual employee training.
At the time of this report, only the operations the City's Public Works Facility is
thought to have potential impact to the City's MS4 system. To reduce any potential
impact, the City will maintain operation and maintenance programs and spill
prevention plans at the Public Works Facility and any other facilities that are
identified later. The City will continue to implement best management practices
(described in Section 6.6.2 and 6.6.3 below) to minimize negative impacts to the
storm drain system. This is accomplished through a process of:
• Observing and inspecting field operations;
• Updating best management practices and SOPS; and
• Training employees.
6.6.2 Inspection and Maintenance Program at Municipal Facilities
The inspection and maintenance program at the City's Public Works Facility
includes:
• Thorough assessment of facility operations and maintenance activities;
• Evaluation of waste disposal and storage methods;
• Evaluation of the stormwater drainage system, including catch basin inlets,
structural best management practices and outfalls;
• Review of spill response and clean up procedures with recommended revisions as
appropriate;
• Evaluation of housekeeping practices with recommended revisions as necessary to
eliminate potential pollution sources;
• Evaluation of outdoor storage areas and recommendations for elimination of
potential pollution sources;
• Identification and elimination of dry weather discharges;
• Review and update (if needed) of the SWPPP; and
• Completion of a written report documenting findings and recommendations.
Follow-up inspections, communication and meetings with appropriate personnel
will be conducted as necessary to eliminate potential pollution sources. Facility
[371

personnel, typically a supervisor and/or management personnel, will participate in
inspections and will be responsible for implementation of SWPPPs and best
management practices.
6.6.3 Street Sweeping Operations
Streets can be a significant source of stormwater pollution, particularly leaves,
which can contribute nitrogen and phosphorus (the City's target pollutants) to local
waterways. In order to address this source, the City will continue to conduct street
sweeping operations. The City will continue to contract with American Road
Conservation to provide quarterly vacuum truck sweeping for all residential areas
where curb and gutter are present. The City will continue to maintain
documentation regarding each sweeping event including miles swept and pounds of
debris collected. The City is in the process of developing an evaluation program for
its street sweeping operation, with the goal of determining the amount of nitrogen
and phosphorus removed from their roadways on an annual basis. This information
will be utilized to determine if street sweeping operations should be adjusted for
future permit years.
6.6.4 Municipal Owned Stormwater Control Measures and MS4
System
The City currently has one municipally owned SCM, located at the Creedmoor
Community Center. This SCM is inspected several times per year. Maintenance is
conducted as needed based on inspection results. Standard inspection forms are
used to conduct and document inspections with this information maintained in a
database.
The City's Public Works staff will continue to conduct cleaning and maintenance of
the MS4 system. Services will include, but will not limited to:
• Catch basin cleaning (manually and with jet trucks);
[381

• Catch basin top cleaning (manually and with jet trucks);
• Stormwater pipe cleaning (by jet truck); and
• Repairs if needed.
Crews will also respond to service requests for cleaning of the MS4 system. All
work will be recorded and maintained in a spreadsheet.
6.6.5 Employee Staff Training
Training will continue to be conducted for employees at the Public Works facility.
The goal of training is to inform employees of the actions necessary to reduce the
discharge of pollutants from their facilities/operations and protect water quality.
Some of the topics that will included in the training are:
• Description of common pollutants, their sources and water quality impacts;
• Description of the actions they should take to reduce discharges of pollutants, with
an emphasis on good housekeeping;
• Description of effective spill response and prevention measures that should be
employed at each facility;
• Discussion of typical pollution sources at municipal operations and specific
actions that should be taken to eliminate these sources and protect water quality;
• Review of the SWPPP where applicable;
• Explanation of the potential negative consequences of failing to control pollutants
at facilities; and
• Overview of IDDE Program and how to report observed water quality problems.
6.6.6 Vehicle and Equipment Cleaning Operations
The City recognizes the negative impacts that vehicle and equipment wash water
runoff can have on stormwater and, ultimately, surface waters. To reduce those
impacts, the City has contracted with AutoBrite Car Washes, Inc. (AutoBrite) to
wash all Police Department, Public Works and Community Development vehicles
[39]

and most larger pieces of vehicle equipment. AutoBrite car washes are self-service
car washes with a discharge capture system.
6.6.7 Program Assessment
The overall success of the Pollution Prevention and Good Housekeeping Program is
evaluated through the successful implementation of the components of the program
and reported with each NPDES MS4 annual report. Additional information
regarding program assessment can be found in Table 6 below.
[40]

Table 6: Pollution Prevention and Good Housekeeping BMPs
BMP
Measurable Goals
Schedule for Implementation
Reporting Metric
a. Inventory of municipally owned or
Maintain, evaluate annually, and update as
The inventory of municipally owned and
Inventory reviewed annually and
operated facilities
necessary an inventory of facilities and
operated facilities has been completed and is
updated as necessary.
operations owned and operated by the
updated annually.
permittee with the potential for generating
polluted stormwater runoff.
b. Inspection and Maintenance (I&M) for
Maintain and implement, evaluate annually
The program has been implemented and
Document number of completed
municipally owned or operated facilities
and update as necessary an I&M program for
maintained and will continue to be evaluated
inspections and maintenance actions.
municipally owned and operated facilities
annually throughout the permit term.
The effectiveness of the I&M program
with the potential for generating polluted
Inspections will be documented annually for
will be evaluated annually and updated
stormwater runoff. The I&M program shall
each facility.
as needed.
specify the frequency of inspections and
routine maintenance requirements.
c. Spill Response Procedures for municipally
Maintain written spill response procedures
Spill response procedures will be evaluated
Document if spill response procedures
owned or operated facilities
for municipal operations.
annually.
have been completed for each facility.
Spill response reviewed annually and
updated as necessary.
d. Streets, roads, and public parking lots
Maintain and implement a program to reduce
Street sweeping of roads and streets is
Provide documentation of sweeping
maintenance
polluted stormwater runoff from
conducted quarterly on all roadways with
events, miles swept and characterize the
municipally -owned streets, roads, and public
curb and gutter.
quantity and composition of the trash
parking lots.
and debris.
e. I&M program for municipally owned
Maintain and implement an I&M program
Implementation of program in place —
Document and report any inspection
catch basins and conveyance systems
for the stormwater sewer system including
evaluate annually and update as needed.
issues, when maintenance is performed
catch basins and conveyance systems that it
and how many inlets on each street are
owns and maintains
inspected. Records to include date of
inspection, inspector, and linear footage
of inspections/maintenance.
f. Identify structural stormwater controls
Maintain a current inventory of municipally-
Inventory and mapping of SCMs at all
Inventory reviewed annually and
owned or operated structural stormwater
facilities within MS4 service area has been
updated as necessary.
controls installed for compliance with the
completed. Inventory will be reviewed
City's Watershed Protection Ordinance.
annually and updated as needed.

Table 6: Pollution Prevention and Good Housekeeping BMPs cont'd
BMP
Measurable Goals
Schedule for Implementation
Reporting Metric
g. I&M program for municipally owned or
Maintain and implement, assess annually and
I&M program for municipal SCMs has been
Document and report number of
maintained structural stormwater controls
update as necessary an I&M program for
implemented. Document inspections and
inspections and maintenance actions
municipally owned or maintained structural
maintenance required annually for each
needed. Document and report
stormwater controls.
facility.
maintenance actions performed.
Document inspections and maintenance of
all municipally -owned or maintained
structural stormwater controls.
h. Pesticide, Herbicide and Fertilizer
Ensure municipal employees and contractors
The training program has been implemented
Document number of staff members
Application Management.
are properly trained and all permits,
and will be conducted annually.
with active certification.
certifications, and other measures for
applicators are followed.
i. Staff Training
Implement an employee training program for
Training program has been implemented.
Document and report who is trained,
employees involved in implementing
Training is documented annually.
number of staff trained, training dates,
pollution prevention and good housekeeping
and topics covered.
practices.
j. Prevent or minimize contamination of
Implement a program to minimize
The City has contracted with AutoBrite Car
Provide documentation regarding
stormwater runoff from all areas used for
contamination of stormwater runoff by
Washes, Inc. to provide vehicle washing that
contracted vehicle washing services
vehicle and equipment cleaning.
vehicle and equipment cleaning.
minimizes contamination of stormwater
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