NCS000431_Conover MS4 AUDIT REPORT_20191022.docx

ROY COOPER
Governor
MICHAEL S. PEGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
October 22, 2019
City of Conover
Attn: Terry Lail, Environmental Coordinator
Post Office Box 549
Conover, North Carolina 28613
Subject: COMPLIANCE AUDIT REPORT TRANSMITTAL
City of Conover
NPDES MS4 Permit No. NCS000431
Catawba County
Dear Mr. Lail:
Enclosed please find the National Pollutant Discharge Elimination System (NPDES) Municipal Separate
Storm Sewer System (MS4) Permit Compliance Audit Report for the subject NPDES MS4 Permit. The
report documents staff findings from the September 26" and 27a', 2019 audit, which evaluated compliance
with the permitted MS4 program administration requirements and the specific minimum control measures
checked below:
® Public Education and Outreach
® Public Involvement and Participation
® Illicit Discharge Detection and Elimination
❑ Construction Site Runoff Controls
M Post -Construction Site Runoff Controls
M Pollution Prevention and Good Housekeeping for Municipal Operations
Reported findings are based upon the documentation provided and staff observations at the time of the audit.
Therefore, this report may not identify all permit compliance issues. The permittee is required to evaluate
program compliance for the program components not checked above and take immediate action to correct all
deficiencies.
Any additional compliance reporting requirements and/or enforcement action by the Department of
Environmental Quality (DEQ) shall be provided under separate cover. Should you have any questions
regarding this MS4 Permit Compliance Audit Report, please feel free to contact me at
Isaiah.Reed(a ncdenr.gov or (821 5�- 14.
Sincer f
Isaiah Reed, MS4C CPSWQ
Environmental Specialist
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
Asheville Regional Office 12090 U.S. Highway 701 Swannanoa, North Carolina 28778
Homes cu�auru
ow.mmmmHma�..ei o.,uir 828.296.4500

Enclosures: DEQ MS4 Program Audit Report (September 26 and 27, 2019, City of Conover)
cc: Jeanette Powell, DEMLR MS4 Program Coordinator
Alaina Morman, DEMLR Stormwater Compliance & Enforcement
DEMLR NPDES MS4 Permit Laserfiche File

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000431
CONOVER, NORTH CAROLINA
Post Office Box 549
Conover, North Carolina 28613
Audit Date: September 26, 2019
Report Date: October 22, 2019
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NCS000431 Conover MS4 Audit 20191022

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
PublicEducation and Outreach.....................................................................................................................7
Public Involvement and Participation...........................................................................................................8
Illicit Discharge Detection and Elimination(IDDE)........................................................................................8
Post -Construction Site Runoff Controls......................................................................................................11
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................15
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................17
Site Visit Evaluation: Municipal Facility No. 2.............................................................................................19
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................21
Site Visit Evaluation: MS4 Outfall No. 2......................................................................................................23
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................25
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000431 Conover M54 Audit 20191022 ii

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NC5000431 Conover M54 Audit 20191022

Audit Details
Audit ID Number:
Audit Date(s):
NCS000431 Conover MS4Audit_20193022
September 26, 2019
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
® Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
® Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 2
® MS4 Outfalls. Number visited: 2
❑ Construction Sites. Number visited: Choose an item.
® Post -Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose an item.
Inspector(s) Conducting Audit
Name. Title
Organization
Isaiah Reed, Environmental Specialist
NCDEQ
Kenny Llywelyn, Environmental Specialist
NCDEQ
Christopher Graybeal, Assistant Regional Engineer
NCDEQ
Audit Report Author•
Date:
Signature
'O
Audit Report Author:
Date
Signature
NCS000431_Conover MS4 Audit_20191022 Page 1 of26

Permittee Information
MS4 Permittee Name:
City of Conover
Permit Effective Date:
February 20, 2017
Permit Expiration Date:
February 19, 2022
Mailing Address:
Post Office Box 549. Conover, North Carolina 28613
Date of Last MS4 Inspection/Audit:
N/A
Co-permittee(s), if applicable:
N/A
Permit Owner of Record:
Donald Duncan, City Manager
Primary MS4 Representatives Participating in Audit
Name, Title
Organization
Terry Lail, Environmental Coordinator
City of Conover
Erik Schlichting, GISP-GIS Specialist
City of Conover
Jimmy Clark, Public Work Director
City of Conover
Terry Jones, Assistant Public Works
Director
City of Conover
Keith Lynch
City of Conover
Alan Glines, APA-Planning Director
City of Conover
MS4 Receiving Waters
Waterbodv
Classification
Impairments
Clark Creek
C
N/A
Cline Creek
C
N/A
Conover Branch
C
N/A
Hildebran Creek
C
N/A
Long Creek
WS-Iv
N/A
Lyle Creek
C
N/A
McLin Creek
C
N/A
Miller Branch
C
N/A
Mull Creek
WS-Iv
N/A
Mahaffie Branch
C
N/A
NCS000431_Conover MS4 Audit_20191022 Page 2 of26

List of Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
2010 SWMP
Prior
2
Administrative Manual
Prior
3
Stormwater Ordinance
Prior
4
IDDE Inspection Form
Prior
5
Vehicle Maintenance Washing Area Inspection Form
Prior
6
Agreement with Western Piedmont Council of Governments
Prior
7
Agreement with Catawba County
Prior
8
Driveway Permit Application / Sedimentation and Erosion Control (<1 Acre)
Permit
Prior
9
Solid Waste Manual of Practice and Operations Summary
Prior
10
Pesticide Use Policy
Prior
11
Spill Prevention, Control and Countermeasures (SPCC) Plan (August 14, 2014)
Prior
12
Stormwater Agreement Form
Prior
13
Stormwater BMP Facility Access Easement
Prior
14
Street Department Operations Summary
Prior
16
2018 Stormwater Annual Report
During
16
IDDE SOP
During
17
Illicit discharge case files for two incidents.
During
18
WPCOG annual report on outreach
During
19
Pet Waste and Stormwater Handouts
During
20
Training Records
During
NCS000431_Conover MS4 Audit_20191022 Page 3 of 26

Program Implementation, Documentation & Assessment
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Permit Citation
Program Requirement
Status
Supporting
Doc No.
II.A.1
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
No
---
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan.
No
---
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided.
No
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page).
Yes
---
A current SWMP has not been maintained. The SWMP contains the names of people who no longer work for the City of Conover.
II.A.2 Stormwater
The permittee evaluated the performance and effectiveness of the program
Plan
components at least annually.
Partial
15
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
components as necessary to accomplish the intent of the Stormwater Program.
No
---
Did the permitted MS4 discharges cause or contribute to non -attainment of an
applicable water quality standard?
No
---
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
the non -attainment?
Applicable
Mr. Lail provided me with a copy of the most recent Annual Report, sent in 2018. However, the annual report did not have all
elements required by the permit.
II.A.3
Keeping the
The permittee kept the Stormwater Plan up to date.
No
1
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
No
---
The SWMP has not been updated since 2010.
The permittee kept an up-to-date version of its Stormwater Plan available to the
Division and the public online.
No
NCS000431_Conover MS4 Audit_20191022 Page 4 of 26

Program Implementation, Documentation & Assessment
II.A.4 Availability
The online materials included ordinances, or other regulatory mechanisms, or a list
See
of the Stormwater
identifying the ordinances, or other regulatory mechanisms, providing the legal
Partial
Commen
Plan
authority necessary to implement and enforce the requirements of the permit.
is
Some of the Code/Ordinance information is available at Library.Municode.com, but all information required by the permit is not
readily accessible online.
II.A.3 & II.A.S
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
Not
Applicable
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
II.A.6 Sharing
Responsibility
Are any control measures implemented by an entity other than the permittee?
Yes
6 and 7
If yes, is there a written agreement in place?
Yes
6 and 7
Public Outreach MCM is conducted by the Western Piedmont Council of Governments. Construction Stormwater MCM is
conducted by Catawba County.
II.A.7
The permittee maintained written procedures for implementing the six minimum
Written
control measures.
No
---
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Partial
1
The SWMP has not been maintained or reviewed.
III. A
The permittee maintained documentation of all program components including, but
Program
not limited to, inspections, maintenance activities, educational programs,
Partial
Various
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
Inspection reports and other documentation were provided. However, various parts of the Stormwater Management Program
are conducted but not documented.
111.13
The permittee submitted annual reports to the Department within twelve months
Annual Report
from the effective date of the permit (See Section III.B. for the annual reporting
Yes
1s
Submittal
period specific to thisMS4).
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal.
Yes
15
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
NCS000431_Conover MS4 Audit_20191022 Page 5 of 26

Program Implementation, Documentation & Assessment
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
15
of each major component of the Stormwater Plan for the past year and
Partial
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
No
15
the proposed changes and how these changes will impact the Stormwater
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
No
15
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
No
15
Stormwater Plan.
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
No
1s
actions.
The Annual Report provided focuses an Public Outreach. The other MCMs described in the report are general overviews and do
not contain all information required by the Permit.
IV.B
Annual Reporting
The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
Partial
15
quantities achieved and summaries of enforcement actions.
2. A description of the effectiveness of each program component.
No
3s
3. Planned activities and changes for the next reporting period, for each
program component or activity.
No
15
4. Fiscal analysis.
No
15
The Annual Report provided focuses on Public Outreach. The other MCMs described in the report are general overviews and do
not contain all information required by the Permit.
Additional
The deficiencies in the above section include, but are not limited to:
Comments:
Failing to maintain an up to date SWMP, documentation of stormwater control activities in the municipalty,
and complete Annual Reports.
NCS000431_Conover MS4 Audit_20191022 Page 6 of26

Public Education and Outreach
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Permit Citation
Program Requirement Status Supporting
Doc No.
II.B.2.a
The permittee defined goals and objectives of the Local Public Education and
Goals and
Outreach Program based on community wide issues.
Objectives
11.B.2.b
The permittee maintained a description of the target pollutants and/or stressors and
Target Pollutants
No ---
likely sources.
A description of the Public Outreach Program has not been maintained. However, the annual report sent to the City of Conover
by the Western Piedmont Stormwater Patnership does contain some information on outreach events were conducted and the
nature of those events. No measurable goals have been maintained and established.
11.B.2.c
The permittee identified, assessed annually and updated the description of the target
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
No
---
An annual assessment of the Public Education and Outreach Program has not been conducted by the Permittee.
11.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Yes
18
Commercial Issues
their education/outreach program.
11.6.2.e
Informational
The permittee promoted and maintained an internet web site designed to convey the
program's message.
No
---
Web Site
The City of Conover did not maintain an internet website describing the outreach efforts.
11.B.2.f
The permittee distributed stormwater educational material to appropriate target
Public Education
Yes
19
Materials
groups.
The Permittee gives out handouts on pet waste and stormwater at community events and makes them available to the public.
II.B.2.e
The permittee promoted and maintained a stormwater hotline/helpline for the
Hotline/Help Line
purpose of public education and outreach.
No
---
No Hotline was maintained for the purpose of Public Education and Outreach.
11.B.2.h
The permittee's outreach program, including those elements implemented locally or
Public Education
through a cooperative agreement, included a combination of approaches designed to
Yes
18
and Outreach
reach the target audiences.
Program
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
No
---
of exposure.
Extent of exposure/exposure hours were not reported.
NCS000431_Conover MS4 Audit_20191022 Page 7 of26

Public Education and Outreach
Additional
The deficiencies in the above section include, but are not limited to:
Comments:
Better documentation of outreach efforts, documentation and establishing goals for the year, and
complete reporting of Public Education and Outreach Efforts in the Annual Reports.
Public Involvement and Participation
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Permit Citation
Program Requirement Status Supporting
Doc No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote
Involvement
Partial
ongoing citizen participation.
Program
The permittee holds several events through the year including: Adopt a Creek, Stormdrain Stenciling, National Night Out
Stormwater Advisory Board, and Litter Sweep. Documentation of these events (participation, time, promotion) has not been
conducted.
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Public
provides for input on stormwater issues and the stormwater program.
Yes
Involvement
stormwater Advisory Board.
II.C2.c
The permittee promoted and maintained a hotline/helpline for the purpose of public
Hotline/Help Line
involvement and participation.
No
---
A hotline was made available on the City's website.
Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title,
Terry Jones, Assistant Public Works Director
Role)
Jimmy Clark, Public Works Director
Permit Citation
Program Requirement Status supporting
Doc No.
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. Partial 16
If yes, the written program includes provisions for program assessment and
integrating Partial 16
evaluation and inte g g program.
NCS000431_Conover MS4 Audit_20191022 Page 8 of 26

Illicit Discharge Detection and Elimination (IDDE)
SOPS were maintained for IDDE, but do not include all information required by the permit.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
II.D.2.b
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Yes
3
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D]
Yes
3
II.D.2.c
The permittee maintained a current map showing major outfalls* and receiving
Storm Sewer
No
---
System Map
streams.
A map of the City's MS4 system including outfalls is still being created.
II.D.2.d
Dry Weather Flow
The permittee maintained a program for conducting dry weather flow field
Program
observations in accordance with written procedures.
A program for conducting dry weather flow field observations has not been created, maintained, or conducted.
II.D.2.e
Investigation
The permittee maintained written procedures for conducting investigations of
Partial
16
Procedures
identified illicit discharges.
SOPS for IDDE were available, but were not sufficient to meet permit requirements.
II.D.2.f
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and
following:
Document
Investigations
1. The date(s) the illicit discharge was observed
Yes
17
2. The results of the investigation
Yes
17
3. Any follow-up of the investigation
No
---
4. The date the investigation was closed
No
---
Thorough inspection reports and notes were maintained, but follow-up and closure were not documented.
II.D.2.l; Employee
The permittee implemented and documented a training P P g program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
Yes
20
contact with or otherwise observe an illicit discharge or illicit connection.
II.D.2.h
The permittee informed public employees of hazards associated with illegal
Public Education
discharges and improper disposal of waste.
Partial
20
NCS000431_Conover MS4 Audit_20191022 Page 9 of 26

Illicit Discharge Detection and Elimination (IDDE)
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste.
No
---
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste.
Yes
19
Municipal employee sign -in sheets were made available during the audit. A more thorough documentation of what the training
included was not available.
II.D.2.i
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Public Reporting
public to report illicit discharges.
Yes
19
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges.
Yes
20
The permittee established and implemented response procedures for citizen
requests/reports.
Partial
16
Incomplete sops for IDDE were available.
II.D.2.1
The permittee implemented a mechanism to track the issuance of notices of violation
Not
Enforcement
and enforcement actions administered by the permittee.
Applicable
--.
If yes, the mechanism includes the ability to identify chronic violators for
Not
initiation of actions to reduce noncompliance.
Applicable
No NOVs have been documented and tracked.
Additional
The primary deficiencies in the above section include, but are not limited to:
Comments:
IDDE events and follow-ups have not been documented appropriately, IDDE SOPS are incomplete, Dry
weather flow inspection schedule has not been created or implemented, a municipal wide M54 map has
not been completed.
NCS000431_Conover MS4 Audit_20191022 Page 10 of26

Post -Construction Site Runoff Controls
Staff Interviewed: Terry Lail, Environmental Coordinator
(Name, Title, Role) Alan Glines, Planning Director
Jimmy Clark, Public Works Director
Implementation (check all that apply):
® The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: name of entity
❑ The permittee implements the following deemed -compliant program(s), which meet NPDES MS4 post -construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below (Complete Session Law 2006-246 section below):
❑ Water Supply Watershed I (WS-1) —15A NCAC 2B .0212
❑ Water Supply Watershed II (WS-II) —15A NCAC 213.0214
❑ Water Supply Watershed III (WS-III) —15A NCAC 2B .0215
❑ Water Supply Watershed IV (WS-IV) —15A NCAC 2B .0216
❑ Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 2B .0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 2B .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 2B .0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
® DEQ model ordinance
❑ MS4 designed past -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed -compliant Program (see list above)
Instructions:
For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed -compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section below for the permitted area(s) not covered under the S. L. 2006-246 deemed -compliant program.
NCS000431—Conover MS4 Audit_20191022 Page 11 of26

Post -Construction Site Runoff Controls
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.F.2.a
The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authority
to meet the objectives of the Post -Construction Site Runoff Controls Stormwater
Yes
3
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part I.D of permit and modify
Yes
3
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Yes
3
control measures will be installed, implemented, and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
evaluate compliance with the Post -Construction Stormwater Management
Yes
3
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
Yes
3
related to stormwater discharges.
II.F.2.b
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Yes
3
Measures (SCMs)
SCMs comply with 15A NCAC 02H .1000.
Yes
3
II.F.2.c
The permittee conducted site plan reviews of all new development and
Plan Reviews
redeveloped sites that disturb greater than or equal to one acre (including sites
that disturb less than one acre that are part of a larger common plan of
Yes
---
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
performance standards.
Yes
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance.
Yes
Site file for Dollar General was reviewed and discussed during the Audit.
II.F.2.d
The permittee maintained an inventory of projects with post -construction
Inventory of Projects
structural stormwater control measures installed and implemented at new
No
---
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post -construction ordinance No ---
requirements.
No inventory was made available during the audit.
NCS000431_Conover MS4 Audit_20191022 Page 12 of26

Post -Construction Site Runoff Controls
II.F.2.e
The permittee provided mechanisms such as recorded deed restrictions and
Deed Restrictions
protective covenants that ensure development activities will maintain the project
No
and Protective
consistent with approved plans.
Covenants
II.F.2.f
The permittee implemented or required an operation and maintenance plan for
Mechanism to
the long-term operation of the SCMs required by the program.
Yes
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCM to perform
Maintenance
and maintain a record of annual inspections of each SCM.
Yes
---
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional.
Yes
---
The site file for Dollar General was reviewed and discussed during the Audit.
II.F.2.e
The permittee conducted and documented inspections of each project site covered
Inspections of
under performance standards, at least one time during the permit term (Verify this
No
Structural
is a permit condition in Part II.F.2.g of permit and modify accordingly).
Stormwater Control
The permittee developed and implemented a written inspection program for SCMs
Measures
installed pursuant to the post -construction program(Verify this is a permit
No
---
condition in Part II.F.2.g of permit and modify accordingly.
The permittee documented and maintained records of inspections.
No
The permittee documented and maintained records of enforcement actions.
No
An inspection program for SCMs had not been developed or implemented at the time of the inspection.
II.F.2.h
The permittee made available through paper or electronic means, ordinances,
Educational
post -construction requirements, design standards checklists, and other materials
Materials and
appropriate for developers.
Training for
Note: New materials may be developed by the permittee, or the permittee may use
Yes
---
Developers
materials adopted from other programs and adapted to the permittee's new
development and redevelopment program.
The site file and submission information for Dollar General was reviewed and discussed during the audit.
II.F.2.1 Enforcement
The permittee tracked the issuance of notices of violation and enforcement
actions.
No
---
If yes, the tracking mechanism included the ability to identify chronic violators
Not
for initiation of actions to reduce noncompliance.
Applicable
No NOVs were documented at the time of the Audit.
II.F.3.b
The permittee fully complies with post construction program requirements on its
Not
New Development
own publicly funded construction projects.
Reviewed
NCS000431_Conover MS4 Audit_20191022 Page 13 of 26

Post -Construction Site Runoff Controls
II.F.3.c
Does the M54 have areas drainingto Nutrient Sensitive Waters NSW
(NSW) pursuant to
Nutrient Sensitive
15A NCAC 02H .0150?
No
---
Waters
If yes, does the permittee use SCMs that reduce nutrient loading in order to
meet local local program requirements.
No
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
No
If yes, does the permittee also require documentation where it is not feasible to
use SCMs that reduce nutrient loading.
No
---
II.F3.d
The permittee ensured that the design volumes of SCMs take into account the
Design Volume
runoff at build out from all surfaces draining to the system.
Yes
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
Yes
streets, driveways, and other impervious surfaces.
The site file for Dollar General was reviewed and discussed during the Audit.
NCS000431_Conover MS4 Audit_20191022 Page 14 of 26

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Terry Jones, Assistant Public Works Director
Jimmy Clark, Public Works Director
Permit Citation
Program Requirement Status Supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted No ---
stormwater runoff.
A written inventory of facilities and potential pollutants has not been maintained.
II.G.2.b
The permittee maintained and implemented an O&M program for municipally
Operation and
owned and operated facilities with the potential for generating polluted
No
---
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
Not
Applicable
If yes, the O&M program specifies the frequency of routine maintenance
Not
requirements.
Applicable
-
If yes, the permittee evaluated the 0&M program annually and updated it as
Not
necessary.
Applicable
A written O&M Plan has not been maintained for the municipally owned facilities.
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Yes
11
Procedures
II.G.2.d Streets,
The permittee evaluated existing and new BMPs that reduce polluted stormwater
Roads, and Public
runoff from municipally -owned streets, roads, and public parking lots within its
No
---
Parking Lots
corporate limits annually.
Maintenance
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Not
based on cost and the estimated quantity of pollutants removed.
Applicable
An evaluation of BMP's was not included in the annual report made available at the time of the audit.
II.G.2.f
O&M for Catch
The permittee maintained and implemented an 0&M program for the stormwater
Basins and
sewer system including catch basins and conveyance systems that it owns and
No
---
Conveyance Systems
maintains.
An O&M plan had not been created and maintained at the time of the audit.
II.G.2.e
The permittee maintained a current inventory of municipally -owned or operated
Structural
structural stormwater controls installed for compliance with the permittee's post-
No
Stormwater Controls
construction ordinance.
An inventory had not been maintained at the time of the audit.
NCS000431_Conover MS4 Audit_20191022 Page 15 of26

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h
The permittee maintained and implemented an O&M program for municipally -
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Not
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
Applicable
The O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
---
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
According to City staff, there are no municipally owned SCMs required under the town's ordinance.
II.G.2.i
The permittee ensured municipal employees are properly trained in pesticide,
Pesticide, Herbicide
herbicide and fertilizer application management.
Yes
---
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Management
fertilizer application management.
Yes
---
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Yes
II.G.2.j
The permittee implemented an employee trainin
P Pg Program for employees involved
Staff Training
in implementing pollution prevention and good housekeeping practices.
Yes
20
II.G.2.k
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
...
Equipment Cleaning
cleaning.
NCS000431_Conover MS4 Audit_20191022 Page 16 of26

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Conover Wastewater Treatment Plant
Date and Time of Site Visit:
September 26, 2019
Facility Address:
3680 Hillview Drive. Conover, NC 28613
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Wastewater Treatment Plant
Name of MS4 inspector(s) evaluated:
Terry Lail
Most Recent MS4 Inspection (List date and name of inspector):
None
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Jimmy Clark
Public Works Administrator
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes. A SWPPP was available related to the facility's NCG110000 permit coverage.
What type of stormwater training do facility employees receive? How often?
Annual SWPPP training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual SWPPP training and re -certification requirements.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspectors process include the use of a checklist or other standardized form?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Does the MS4 inspector's process include taking photos?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos, and reviewing the
facility's SWPPP.
NCS000431_Conover MS4 Audit_20191022 Page 17 of 26

Site Visit Evaluation: Municipal Facility No. 1
Does the M54 inspector's process include walking the entire facility and inspecting all points of discharge?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos, and contacting
the site personnel.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes. Damage to a conveyor resulting in waste material getting deposited on the ground. Mr. Lail will follow up on corrective
actions with the facility personnel.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
Not decided at the time of the inspection.
NCS000431_Conover MS4 Audit_20191022 Page 18 of 26

Site Visit Evaluation: Municipal Facility No. 2
Facility Name:
Public Works
Date and Time of Site Visit:
September 27, 2019
Facility Address:
939 4" Street SW. Conover, NC
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Vehicle maintenance, Landscaping, etc.
Name of MS4 inspector(s) evaluated:
Terry Lail
Most Recent MS4 Inspection (Date and Entity):
None
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Jimmy Clark
Public Works Director
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
NO
What type of stormwater training do facility employees receive? How often?
Annual SW training.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual SWPPP Training.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Does the MS4 inspectors process include taking photos?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos, and will review
the SWPPP.
NCS000431_Conover MS4 Audit_20191022 Page 19 of 26

Site Visit Evaluation: Municipal Facility No. 2
Does the M54 inspector's process include walking the entire facility and inspecting all points of discharge?
This was the inspectors first M54 inspection. Future inspections shall include the use of a checklist and photos.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
Yes. The facility must be covered under an NPDES General Permit, and secondary containment has not be provided for all bulk
storage of liquid materials. Other issues were also observed.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
To be determined at a later date by City staff.
Notes/Comments/Recommendations
NCS000431_Conover MS4 Audit_20191022 Page 20 of 26

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
None given
September 27, 2019
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
310 Second Street NE. Conover, NC
Pipe and drainage channel
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Mahaffie Branch
Sheen, Odor, Floatables/Debris, etc.):
No
Most Recent Outfall Inspection/Screening (Date):
None
Days Since Last Rainfall:
Inches:
Not Evaluated
Name of MS4lnspector(s) evaluated:
Terry Lail
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual SW Training.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Does the inspector's process include taking photos?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
NCS000431_Conover MS4 Audit_20191022 Page 21 of 26

Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
Erosion near the street.
Will a follow-up outfall inspection be conducted? If so, for what reason?
Yes. To be determined by the M54 Inspector.
NCS000431_Conover MS4 Audit_20191022 Page 22 of26

Site Visit Evaluation: MS4 Outfall No. 2
Outfall ID Number:
Date and Time of Site Visit:
None Given
September 27, 2019
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
361 Fifth Street SE. Conover, NC
Drainage channel and metal pipe.
Receiving Water: Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
McLin Creek Sheen, Odor, Floatables/Debris, etc.):
Most Recent Outfall Inspection/Screening (Date): None
None
Days Since Last Rainfall: Inches:
Not evaluated
Name of MS4lnspector(s):
Terry Lail
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual SW Training.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form? Obtain copy.
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Does the inspector's process include taking photos?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No
NCS000431_Conover MS4 Audit_20191022 Page 23 of26

Site Visit Evaluation: MS4 Outfall No. 2
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No
Will a follow-up outfall inspection be conducted? If so, for what reason?
No
NCS000431_Conover MS4 Audit_20191022 Page 24 of 26

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Dollar General
Date and Time of Site Visit:
September 27, 2019
Site Address:
1200 l't Street West. Hickory
SCM Type:
Dry pond
Most Recent MS4 Inspection (Include Date and Entity):
None
Name of MS4lnspector(s) evaluated:
Terry Lail
Most Recent MS4 Enforcement Activity (Include Date):
None
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
None
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes
Does the site have records of annual inspections? Are they performed by a qualified individual?
No
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Annual SW Training.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
Yes
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M
requirements, etc.)?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
Does the MS4 inspector's process include taking photos?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist and photos.
NCS000431_Conover M54 Audit_20191022 Page 25 of26

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
This was the inspectors first MS4 inspection. Future inspections shall include the use of a checklist, file review and photos.
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No
Does the MS4 inspectors process include presenting the inspection findings to the site contact in writing?
Not evaluated.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
None
If compliance issues were identified, what timeline for correction/follow-up was provided?
None
NCS000431_Conover MS4 Audit_20191022 Page 26 of 26