NCS000431_Conover Draft Final SWMP_20210212

STORMWATER MANAGEMENT PLAN

NPDES NCS000431 Prepared by:
January 27, 2021

Table of Contents

PART 1: INTRODUCTION ........................................................................................................................ 1

PART 2: CERTIFICATION ........................................................................................................................ 2

PART 3: MS4 INFORMATION .................................................................................................................. 3
3.1 Permitted MS4 Area ..................................................................................................................... 3
3.2 Existing MS4 Mapping ................................................................................................................. 4
3.3 Receiving Waters .......................................................................................................................... 5
3.4 MS4 Interconnection ..................................................................................................................... 6
3.5 Total Maximum Daily Loads (TMDLs) ....................................................................................... 6
3.6 Endangered and Threatened Species and Critical Habitat ............................................................ 7
3.7 Industrial Facility Discharges ....................................................................................................... 7
3.8 Non-Stormwater Discharges ......................................................................................................... 8
3.9 Target Pollutants and Sources ....................................................................................................... 9

PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 12
4.1 Organizational Structure ............................................................................................................. 12
4.2 Program Funding and Budget ..................................................................................................... 14
4.3 Shared Responsibility ................................................................................................................. 15
4.4 Co-Permittees .............................................................................................................................. 16
4.5 Measurable Goals for Program Administration .......................................................................... 16

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 18

PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 25

PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 30

PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................... 40

PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 43

PART 10:POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ....................... 49

List of Tables

Table 1: Summary of MS4 Mapping
Table 2: Summary of MS4 Receiving Waters
Table 3: Summary of Approved TMDLs
Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Table 5: NPDES Stormwater Permitted Industrial Facilities
Table 6: Non-Stormwater Discharges
Table 7: Summary of Target Pollutants and Sources
Table 8: Summary of Responsible Parties
Table 9: Shared Responsibilities
Table 10: Co-Permittee Contact Information
Table 11: Program Administration BMPs
Table 12: Summary of Target Pollutants & Audiences
Table 13: Public Education and Outreach BMPs
Table 14: Public Involvement and Participation BMPs
Table 15: Illicit Discharge Detection and Elimination BMPs
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Table 17: Construction Site Runoff Control BMPs
Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program
Table 19: Summary of Existing Post-Construction Program Elements
Table 20: Post Construction Site Runoff Control BMPs
Table 21: Pollution Prevention and Good Housekeeping BMPs

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City of Conover
January 27, 2021
Page 1

PART 1: INTRODUCTION

The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the City of
Conover will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm
Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of
reducing pollutants in stormwater runoff to the maximum extent practicable.

This SWMP identifies the specific elements and minimum measures that the City of Conover will develop, implement,
enforce, evaluate, and report to the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy,
Minerals and Land Resources (DEMLR) in order to comply with the MS4 Permit number NCS000488, as issued by
NCDEQ. This permit covers activities associated with the discharge of stormwater from the MS4 as owned and operated
by the City of Conover and located within the corporate limits of the City of Conover.

In preparing this SWMP, the City of Conover has evaluated its MS4 and the permit requirements to develop a
comprehensive 5-year SWMP that will meet the community’s needs, address local water quality issues and provide the
minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated annually to ensure
that the elements and minimum measures it contains continue to adequately provide for permit compliance and the
community’s needs.

Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along with any
approved modifications of the SWMP, are incorporated by reference into the permit and become enforceable parts of the
permit.

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PART 2: CERTIFICATION

By my signature below I hereby certify, under penalty of law, that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief,
true, accurate, and complete.

I am aware that there are significant penalties for submitting false information, including the possibility of fines and
imprisonment for knowing violations.

I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4 Permit, and that
both the Division and the Environmental Protection Agency have NPDES MS4 Permit compliance and enforcement
authority.

☒ I am a principal executive officer or ranking elected official.
☐ I am a duly authorized representative and have attached the authorization made in writing by a principal executive
officer or ranking elected official which specifies me as:
☐ A specific individual having overall responsibility for stormwater matters.
☐ A specific position having overall responsibility for stormwater matters.

Signature:

Name: Donald Duncan

Title: City Manager

Signed this ____ day of January 2020.

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City of Conover
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Page 3

PART 3: MS4 INFORMATION

3.1 Permitted MS4 Area
This Stormwater Management Plan (SWMP) applies throughout the corporate limits of the City of Conover, including all
regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits
of City of Conover as of the date of this document.

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3.2 Existing MS4 Mapping
The current MS4 mapping includes outfalls located within the City of Conover. In the future, the City will be adding the
following elements to the map: stormwater conveyances, flow directions, and receiving streams. This is addressed in
development, funding, and maintenance in Permit Reference 3.4.1 BMP 19.

The City of Conover has a historic count of 153 outfalls per the GIS layer created; however it is not certain that all of
these are major per the definition provided below. The City will be verifying all elements, as mentioned above, in the
completion of BMP 19.B.1 addresses the verification of the existing data, and BMP 19.B.3-4 addresses the updating of the
existing map, as well as, adding additional infrastructure as it comes in.

Table 1: Summary of MS4 Mapping
Percent of MS4 Area Mapped 90 %
No. of Major Outfalls* Mapped 153 Total

*An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch) directly into surface
waters. Major outfalls are required to be mapped to meet permit requirements. A major outfall is a 36-inch diameter
pipe or discharge from a drainage area > 50-acres; and for industrial zoned areas a 12-inch diameter pipe or a drainage
area > 2-acres.

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3.3 Receiving Waters
The City of Conover MS4 is located within the Catawba River Basin and discharges directly into receiving waters as
listed in Table 2 below. Applicable water quality standards listed below are compiled from the following NCDEQ
sources:

o Waterbody Classification Map
o Impaired Waters and TMDL Map
o Most recent NCDEQ Final 303(d) List

Table 2: Summary of MS4 Receiving Waters
Receiving Water Name
Stream
Index / AU
Number
Water
Quality
Classification
303(d) Listed Parameter(s)
of Interest
Clark Creek 13-17-4 C N/A
Cline Creek 11-129-5-2 C N/A
Conover Branch 11-129-5-2-
1 C N/A
Hildebran Creek 11-129-5-3 C N/A
Long Creek 11-120-
(0.5) WS-IV N/A
Lyle Creek 11-76-(0.5) C N/A
McLin Creek 11-76-5-
(0.3) C N/A
Miller Branch 11-129-5-1 C N/A
Mull Creek 11-76-4 WS-IV N/A
Mahaffie Branch 11-76-2 C N/A

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3.4 MS4 Interconnection
The City of Conover MS4 is not interconnected with another regulated MS4.
3.5 Total Maximum Daily Loads (TMDLs)
The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map and list
provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates whether the approved TMDL
has a specific stormwater Waste Load Allocation (WLA) for any watershed directly receiving discharges from the
permitted MS4, and whether a Water Quality Recovery Program has been implemented to address the WLA. Outreach
education and stream cleanup helps with the reduction of waste load allocation with approved TMDL municipalities.

Table 3: Summary of Approved TMDLs
Water Body Name TMDL Pollutant Stormwater
Waste
Load
Allocation
(Y/N)
Water
Quality
Recovery
Program
(Y/N)
Statewide Mercury N N
Clark Creek Fecal coliform Y N

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3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or critical habitat are identified within the regulated MS4
urbanized area, as determined by a review of the Endangered and Threatened Species and Species of Concern by County
for North Carolina Map and Listed species believe to or known to occur in North Carolina map as provided by the U.S.
Fish and Wildlife Service. Of those species listed, Table 4 summarizes the species that may be significantly impacted by
the quality of surface waters within their habitat.

Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality

Scientific Name Common name Species Group Federal Listing
Status
Haliaeetus leucocephalus Bald eagle Vertebrate Bald and Golden
Eagle Protection Act
Glyptemys muhlenbergii Bog turtle Vertebrate Threatened due to
similarity in
appearance
Glaucomys sabrinus
coloratus
Carolina northern
flying squirrel
Vertebrate Endangered
Myotis septentrionalis Northern long-eared
bat
Vertebrate Threatened
Alasmidonta varicosa Carolina hemlock Vascular Plant At risk species
Hexastylis naniflora Dwarf-flowered
heartleaf
Vascular Plant Threatened
Helianthus schweinitzii Schweinitz's
sunflower
Vascular Plant Endangered

3.7 Industrial Facility Discharges
The City of Conover MS4 jurisdictional area includes the following industrial facilities which hold NPDES Industrial
Stormwater Permits, as determined from the NCDEQ Active NPDES Stormwater Permit List and/or Active Stormwater
Permits Map.

Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number Facility Name
NCG030105 Prodelin Corp-Conover
NCG050072 Carpenter Co - Conover
NCG050101 Armacell LLC-Conover Plant
NCG050190 Elite Comfort Solutions
NCG050327 Pregis PolyMask
NCG030673 Hickory Springs Manufacturing -Conover Complex
NCG030680 General Dynamics Mission Systems SATCOM
NCG050402 WestRock Converting Company
NCG080976 Old Dominion Freight Line Inc - HKY

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NCG080428 PJF Southeast, LLC
NCG080285 Zenith Freight Lines LLC
NCG100036 Schronce Used Parts and Cars Inc.
NCG080304 UPS Ground Freight, Inc.-Conover
NCG080911 XPO Logistics Freight, Inc. - NHN
NCG080318 Wilson Trucking Corp-Conover
NCG080428 PJF Southeast, LLC
NCG110145 Northeast WWTP
NCG130044 Republic Services of NC, LLC-GDS-Conover-MRF
NCG160003 J.T. Russell & Sons, Inc.
NCG210330 Tradewinds International Inc
NCG210147 Terra Mulch Products LLC
NCG180012 Vanguard Furniture Co Incorporated
NCG180023 Craftwork Guild Plant
NCG180073 Classic Leather Incorporated
NCG180085 Craftwork Guild Plant
NCG180114 Southern Furniture Co-Plant 1
NCG180118 Southern Furniture Co-Plant 2
NCG180227 Kroehler Furniture Mfg Co Inc
TBD City of Conover Public Works Facility

3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the City of Conover as summarized in
Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. The
City of Conover has evaluated residential and charity car washing for possible significant water quality impacts. Street
cleaning is performed with dry street sweeping process; however construction sites occasionally with clean the streets
with potable water as directed by NCDOT and Erosion Control requirements.

The Division has not required that other non-stormwater flows be specifically controlled by the City of Conover.

Wash water associated with car washing that does not contain detergents/surfactants or does not discharge directly into the
MS4 is considered incidental. However, these types of non-stormwater discharges that do contain detergents/surfactants
have been evaluated by the City of Conover to determine whether they may significantly impact water quality. The City
of Conover will address the possibility of the below mentioned water quality impacts through public education and good
housekeeping, as outlined in Part 5 BMP 3-8 and Part 10 BMP 45-47, 49, 52-54, 56, 57 and 61 with focusing on good
housekeeping training and practices.

Table 6: Non-Stormwater Discharges
Non-Stormwater Discharge Water Quality Impacts
Water line and fire hydrant flushing Incidental
Landscape irrigation Incidental
Diverted stream flows Incidental
Rising groundwater Incidental
Uncontaminated groundwater infiltration Incidental

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Uncontaminated pumped groundwater Incidental
Uncontaminated potable water sources Incidental
Foundation drains Incidental
Air conditioning condensate Incidental
Irrigation waters Incidental
Springs Incidental
Water from crawl space pumps Incidental
Footing drains Incidental
Lawn watering Incidental
Residential and charity car washing Possible
Flows from riparian habitats and wetlands Incidental
De-chlorinated swimming pool discharges Incidental
Street wash water Possible
Flows from firefighting activities Incidental

3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the City of Conover is aware of other significant water quality
issues within the permitted MS4 area. Target pollutants as listed below are contributors of the stream impairment.

Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the likely
activities/sources/targeted audiences attributed to each pollutant, and identifies the associated SWMP program(s) that
address the target pollutants. In addition, the City of Conover has observed and evaluated: schools, homeowners,
businesses, industrial sites, farming, construction activities, and public employees as target audiences that are likely to
have significant stormwater impacts. Within the table and list below the following target pollutants have been found to be
concerns within the community.
Litter: Roadside litter is an ongoing issue for the City. This litter poses a threat to both our water bodies and the MS4
infrastructure, as the litter can create clogs and backups that damage the pipelines/conveyances that lead back to the
stream. Some litter even poses a threat to groundwater if chemical leaching or breakdown of components into heavy
metals occurs due to weathering of the litter. Most litter is found on the side of major roads, around school facilities, and
certain businesses.
Sediment: Sediment buildup is largely attributed to mismanaged construction sites with fallen or incorrectly installed
sediment fences. Erosion control fences failing or being improperly maintained. This has led to sediment buildup near
storm drains, onto down slope private properties, and in some cases causing water to build up in nearby properties as the
sediment is limiting the drains ability to remove runoff. In all cases the city has responded and had the issue solved, but
even being down for a short time can have significant effects. Erosion control fences are required for sediment control
permits during construction by the DEQ throughout the entire construction process.
Gray Water: In the past a few residents have been found with washing machines straight-piped out of their homes by
using water hoses exiting windows. Homes are to be connected to the appropriate sewer system. This proves to be a
source of detergents/soaps entering our storm drains in residential neighborhoods. In addition: residential, charity, and
municipal car washes allow for soaps or waxes to enter the storm drain when vehicles are not being cleaned in the correct
areas (such as vegetated patches or in areas that do not have storm drains). This allows for toxic contaminants to enter
waterways via the storm drain system.
Fats Oils and Grease: Can become an issue when grease traps are not appropriately maintained. This has led to cases of
the restaurants allowing the grease to drip onto nearby impermeable surface – which would eventually lead to water

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quality issues. Overflow from a lack of maintenance or throwing out the grease with general waste contributes to this
problem. This is a health violation since the grease poses a physical risk, but it also can impair water bodies with an influx
of water insoluble grease going down the storm drain. In all cases, code enforcement has responded and the issues have
been remedied.
Chemicals: Industrial sites housing totes/containers of unknown/unmarked chemicals can lead to potential soil and water
contamination, and/or incorrect spill cleanup procedure. Totes/containers are to be correctly stored in a way to minimize
risk to the water bodies from seepage, damage to the containers, or spills. Any reports Code enforcement has responded.
Animal Operations: Animal operations are agriculture operations that raise cows, pigs, chickens, or other
livestock as a product, be it from meat or byproducts of the animal, the latter being more problematic as the
excess nutrients will lead to eutrophication which can eventually causing hypoxia in the water body. In a similar
vein, agricultural runoff often caries excess fertilizer which also will cause eutrophication in streams with its
cascading effects.
Underground storage tanks: Storage devices installed below ground can contain gasoline, fuels such as propane,
industrial chemicals/oils, and most often human waste (fecal coliform) in areas not directly connected to the sanitary
sewer. Any underground storage tank must be well maintained/monitored, and correctly installed due to the risk of them
leaking. The leaks can cause whatever chemical the tank is storing to leak into the ground, harming the soil,
groundwater/water table, and even surface waters as they are being fed from groundwater. If a fuel or industrial chemical
tank is leaking, the chemical will leach into the soil – leading to toxic soil, contaminated groundwater, and possibly
impairing a stream/water body.
Some areas of the City still have homes that utilize septic tanks. If a septic tank is leaking, it create nutrient overloads in
streams fed by groundwater, or allowing pathogens to enter, increasing the risk of disease. When septic tank failure is
noted, the home is required to connect to sanitary sewer where available. By properly managing and enforcing septic
tanks, fecal coliform can be reduced in receiving streams within/near the City.
Illicit discharges: Typically, illicit discharges come from businesses, residents or municipal facilities who dump
chemicals into storm drains either incidentally due to a lack of IDDE education or general carelessness. These chemicals
can vary greatly, and can include grease, oils, chemicals, cleaning solutions, paints, metals, etc. This is a recognized
problem as we have several streams impaired from causes related to substances or attributions given to unclean discharges
into the streams - in addition to reports generated by the municipality
Illegal dumping: Waste dumped randomly in non-permitted dumping areas, can cause a variety of problems. For
example, citizens dumping televisions on the side of the road to avoid dumping fees, which allows for the metals or
chemicals inside TVs to leach out as stormwater passes it (mercury, lead, and other metals). It can be a case of businesses
dumping waste in watershed areas where runoff passes through the waste, either carrying it, or residuals of the waste into
water bodies. It can also be a case of graders dumping sediment into areas without the correct allowances/precautions. The
debris and chemicals accumulate over time and lead to chemical impairments, pH issues, turbidity impairments, or debris
entering the stream/MS4 system. The City provides municipal residential solid waste pick-up weekly to all City residents.
Improper disposal of waste: Allows chemicals, or difficult to manage waste, to enter the environment in ways that may
be hard to track. For example; not giving a car battery to the correct waste management facility can allow for battery acid
and lead to enter the soil which drains/collects in the groundwater. These types of problems have been noticed by
municipal waste managers and can be difficult to track since the improperly disposed waste is mixed in with the standard
refuse. Other examples include grease going down sinks clogging sanitary MS4 systems, chemicals from batteries
leaching into the groundwater, oil from oil changes not going to the correct facility, etc.

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While some of the target audiences are not as prominently found within the City, it is still important to educate because
they can be likely sources of non-point pollution through uninformed management practices.
Table 7: Summary of Target Pollutants and Sources
Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing
Target Pollutant(s)/Audience(s)
Litter Residents, Businesses, Schools Public Education & Outreach
Public Participation
Sediment Construction Activity Public Education & Outreach,
Construction Program
Post-construction Program
Fecal coliform Sewer overflows, failing septic
systems, wildlife, illicit discharge
Public Education & Outreach,
Illicit Discharge
Gray water Residential Illicit Discharge
Public Education & Outreach
Fats, Oils and Grease Businesses (Restaurants) Illicit Discharge
Public Education & Outreach
Chemicals Industrial, Business and Residential Illicit Discharge
Public Education & Outreach
Good Housekeeping
Animal Operations Urban Farming Illicit Discharge
Public Education & Outreach
Underground Storage Tanks Business and Residents Illicit Discharge
Public Education & Outreach
Illicit Discharges General Public, Businesses,
Municipal Employees
Illicit Discharge
Public Education & Outreach
Good Housekeeping
Illegal Dumping and
Improper Disposal of Waste
General Public, Businesses,
Municipal Employees
Illicit Discharge
Public Education & Outreach
Good Housekeeping

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PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION

4.1 Organizational Structure
The City of Conover has contracted Western Piedmont Council of Governments (WPCOG) to coordinate Stormwater
Management Plan efforts, to ensure the City is facilitating Best Management Practices (BMPs) to protect water quality.
While WPCOG will be the primary operator of the program the City of Conover staff will be trained to handle internal
procedures and report action/s to WPCOG. The following organizational chart is broken down by the six elements
associated with Stormwater Management. Each of the positions under the elements will report back to the primary
manager and then on to the Stormwater Administrator.

Table 8: Summary of Responsible Parties
SWMP Component Responsible Position Staff Name Department
Stormwater Program
Administration
City Manager

Environmental Coordinator/
Construction Manager
Donald Duncan

Terry Lail
Administration, City of
Conover

Planning, City of
Conover
SWMP Management Environmental Coordinator/
Construction Manager

Senior Planner/Natural
Resources Administrator
Terry Lail

Johnny Wear (support
contracted staff)
Planning, City of
Conover

Planning, WPCOG

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Public Education &
Outreach
Environmental Coordinator/
Construction Manager

Senior Planner/Natural
Resources Administrator
Terry Lail

Johnny Wear (support
contracted staff)
Planning, City of
Conover

Planning, WPCOG
Public Involvement
& Participation
Environmental Coordinator/
Construction Manager

Senior Planner/Natural
Resources Administrator
Terry Lail

Johnny Wear (support
contracted staff)
Planning, City of
Conover

Planning, WPCOG
Illicit Discharge
Detection &
Elimination
Environmental Coordinator/
Construction Manager

Stormwater Administrator
Terry Lail

Jack Cline (support
contracted staff)
Planning, City of
Conover

Planning, WPCOG
Construction Site
Runoff Control
Environmental
Coordinator/Construction
Manager

Erosion Control Manager
Terry Lail

Varies – inspector
availability
City of Conover
(See 4.3 for further
detail)

Catawba County
Erosion Control Office
Post-Construction
Stormwater
Management
Environmental Coordinator/
Construction Manager

Stormwater Administrator
Terry Lail

Jack Cline (support
contracted staff)
Planning, City of
Conover

Planning, WPCOG
Pollution
Prevention/Good
Housekeeping for
Municipal Operations
Environmental Coordinator/
Construction Manager

Senior Planner/Natural
Resources Administrator
Terry Lail

Johnny Wear (support
contracted staff)
Planning, City of
Conover

Planning, WPCOG
Municipal Facilities
Operation &
Maintenance
Program
Environmental Coordinator/
Construction Manager

Director of Public Works

Stormwater Administrator
Terry Lail

Jimmy Clark

Jack Cline (support
contracted staff)
Planning, City of
Conover

Public Works, City of
Conover

Planning, WPCOG
Spill Response
Program
Environmental Coordinator/
Construction Manager

Fire Department Chief

Stormwater Administrator
Terry Lail

Mark Hinson

Jack Cline (support
contracted staff)
Planning, City of
Conover

Fire, City of Conover

Planning, WPCOG
MS4 Operation &
Maintenance
Program
Environmental Coordinator/
Construction Manager

Director of Public Works
Terry Lail

Jimmy Clark
Planning, City of
Conover

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Stormwater Administrator

Jack Cline (support
contracted staff)
Public Works, City of
Conover

Planning, WPCOG
Municipal SCM
Operation &
Maintenance
Program
Environmental Coordinator/
Construction Manager

Director of Public Works

Stormwater Administrator
Terry Lail

Jimmy Clark

Jack Cline (support
contracted staff)
Planning, City of
Conover

Public Works, City of
Conover

Planning, WPCOG
Pesticide, Herbicide
& Fertilizer
Management
Program
Environmental Coordinator/
Construction Manager

Director of Public Works
Terry Lail

Jimmy Clark
Planning, City of
Conover

Public Works, City of
Conover
Vehicle & Equipment
Cleaning Program
Environmental Coordinator/
Construction Manager

Director of Public Works
Terry Lail

Jimmy Clark
Planning, City of
Conover

Public Works, City of
Conover
Pavement
Management
Program
Environmental Coordinator/
Construction Manager

Director of Public Works
Terry Lail

Jimmy Clark
Planning, City of
Conover

Public Works, City of
Conover

4.2 Program Funding and Budget
In accordance with the issued permit, the City of Conover shall maintain adequate funding and staffing to implement and
manage the provisions of the SWMP and comply with the requirements of the NPDES MS4 Permit. The budget includes
the permit administration and compliance fee, which is billed by DEQ annually.

The City of Conover’s Environmental Coordinator/Construction manager’s salary one-third is covered by stormwater and
two-thirds by water and waste water fees. To help cover support expenses Public Works allocated 180,000 from General
Fund and Utility Monies. Leaf collection is complete by City Sanitation Staff and temporary contract workers. During the
non-leaf season Grounds oversees the litter sweep, with $21,500 allocated.

The City of Conover has a two-year contract (which will need to be modified, adopted, and signed every two years) with
Western Piedmont Council of Governments for the following support services: Public Education and Outreach Program,
Public Involvement and Participation Program, Illicit Discharge Detection and Elimination Program, Post-Construction
Site Runoff Control Program, and Pollution Prevention and Good Housekeeping Programs. The current contract amount
for the 2-year period (years 1 and 2 of the NPDES permit cycle) is $53,354.00 of general funds being used. The City will
be responsible for the cost of the annual NPDES permit renewal, which is to be paid to the state. Any fees charged to the
development community for BMP Inspections, Plan Review, and other associated fees will be used to help offset cost.
The City may determine that stormwater utility fees should be implemented; these fees would be collected by the City
through utility bills.

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Should the City of Conover choose not to renew the existing two-year contract, prior to the last month, a revision to the
existing NPDES permit and Stormwater Management Plan would need to occur. The City of Conover would be required
to renew the two-year contract, in years 2022 and 2024, to fully carry out the 5 year NPDES permit cycle.

4.3 Shared Responsibility
The City of Conover will be responsibility, with WPCOG (referred to as entity) providing support service, to implement
the following minimum control measures, which are as stringent as the corresponding NPDES MS4 Permit requirement.
The City of Conover remains responsible for compliance if the other entities fail to perform the permit obligation and both
may be subject to enforcement action, if neither the City of Conover, nor the other entities fully perform the permit
obligation. Table 9 below summarizes individual responsibilities for each program.

Table 9: Shared Responsibilities
SWMP BMP or
Permit Reference Implementing Entity & Program Name
Legal
Agreement
(Y/N)
General Requirements WPCOG Stormwater Program Planning and Administration Y
Public Education and
Outreach Program
WPCOG Stormwater Program Planning and Administration Y
Public Involvement and
Participation Program
WPCOG Stormwater Program Planning and Administration Y
Illicit Discharge Detection
and Elimination Program
WPCOG Stormwater Program Planning and Administration Y

Construction Site Runoff
Control Program
Catawba County Delegated SPCA Program Y
Post-Construction Site
Runoff Control Program
WPCOG Stormwater Program Planning and Administration Y
Pollution Prevention and
Good Housekeeping
Programs
WPCOG Stormwater Program Planning and Administration Y
Total Maximum Daily Load
(TMDL)
WPCOG Stormwater Program Planning and Administration Y

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
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4.4 Co-Permittees
There are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000431 for the
City of Conover.

4.5 Measurable Goals for Program Administration
In response to the DEQ MS4 Audit completed in 2018 for the City of Conover - Program Implementation, Documentation
& Assessment (II.A2, II.A.3, II.A.4, II.A.7, III.A., III.B., IV.B. ) the following changes are being implemented.
Per BMP 1 the SWMP will be reviewed on an annual basis to determine if any updates need to occur. All documents
associated to the Stormwater program will be accessible online, either via the City of Conover website or the Western
Piedmont Council of Governments Stormwater Partnership webpage (reference BMP 14 and 30). Documentation of all
actions related to stormwater activities (as mentioned below) will be recorded, so staff can track and evaluate the
effectiveness of each program component.

The City of Conover will manage and report the following Best Management Practices (BMPs) for the administration of
the Stormwater Management Program using Public Education & Outreach, Public Involvement & Participation, Illicit
Discharge Detection & Elimination, Post-Construction Site Runoff Control, and Pollution Prevention & Good
Housekeeping.

Table 11: Program Administration BMPs
Permit
Ref.
2.1.2 and Part 4: Annual Self-Assessment
Measures to evaluate the performance and effectiveness of the SWMP program components at least annually.
Results shall be used by the permittee to modify the program components as necessary to accomplish the intent
of the Stormwater Program. The self-assessment reporting period is the fiscal year (July 1 – June 30).
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
1. Annual Self-Assessment
Perform an annual evaluation of
SWMP implementation,
suitability of SWMP
commitments and any proposed
changes to the SWMP utilizing
the NCDEQ Annual Self-
Assessment Template.
1. Prepare, certify, and
submit the Annual
Self-Assessment to
NCDEQ prior to
August 31 each year.
1. Annually for Permit
Years 1 – 4

1. Annual Self-
Assessment received
by NCDEQ no later
than August 31 each
year.
Permit
Ref.
1.6: Permit Renewal Application
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
2. Permit Renewal Application

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
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Table 11: Program Administration BMPs
Audit stormwater program
implementation for compliance
with the permit and approved
SWMP, and utilize the results to
prepare and submit a permit
renewal application package.
1. Participate in an
NPDES MS4 Permit
Compliance Audit, as
scheduled and
performed by EPA or
NCDEQ.
1. TBD – Typically
Permit Year 4

1. N/A
2. Self-audit and
document any
stormwater program
components not
audited by EPA or
NCDEQ utilizing the
DEQ Audit Template.
2. Permit Year 5

2. Submit Self-Audit
to DEMLR (required
component of permit
renewal application
package).
3. Certify and submit
the stormwater permit
renewal application
(NOI, Self-Audit, and
Draft SWMP for the
next 5-year permit
cycle).
3. Permit Year 5

3. Permit renewal
application package
received by DEQ at
least 180 days prior to
permit expiration.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 18

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The City of Conover will implement a Public Education and Outreach Program to distribute educational materials to the
community or conduct equivalent outreach activities about the impacts of stormwater discharges into water bodies and
steps the public can take to reduce pollutants in stormwater runoff.

The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by the Public
Education and Outreach Program, are summarized in Table 12 below. In addition, the City of Conover is required to
inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping and improper
disposal of waste. The City will take a proactive approach in reporting the amount and to whom is reached through public
education and outreach efforts.

Table 12: Summary of Target Pollutants & Audiences
Target Pollutants/Sources Target Audience(s)
Litter Residents, Businesses, Schools
Sediment Construction Activity
Fecal Coliform Residents, Businesses, Schools
Gray Water Residents
Fats, Oils and Grease Businesses (Restaurants)
Animal Operations Bona fide farms/Urban Farming
Underground Storage Tanks Businesses and Residents
Chemicals Industrial, Business and Residents
Illicit Discharges General Public, Businesses, Municipal Employees
Illegal Dumping General Public, Businesses, Municipal Employees
Improper Disposal of Waste General Public, Businesses, Municipal Employees

The City of Conover will manage, implement and report the following public education and outreach BMPs.

Table 13: Public Education and Outreach BMPs
Permit
Ref.
3.2: Outreach to Targeted Audiences
Measures to identify the specific elements and implementation of a Public Education and Outreach Program to
share educational materials to the community or conduct equivalent outreach activities about the impacts of
stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The
permittee shall document the extent of exposure of each media, event or activity, including those elements
implemented locally or through a cooperative agreement.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
3. Stormwater Fliers
Stormwater fliers will be
distributed to City residences,
municipal employees, businesses,
and industrial facilities through
stormwater events. Five topics
will be addressed over the term of
the permit; general stormwater
1. Develop and
distribute fliers at City
events to create
stormwater awareness.
1. Permit Year 1

1.-5. Number of flyers
distributed at each
event.
2. Develop and
distribute a fliers for
illicit discharges.
2. Permit Year 2

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City of Conover
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Table 13: Public Education and Outreach BMPs
awareness, illicit discharges,
illegal dumping, chemicals and
proper disposal of waste.

3. Develop and
distribute a fliers for
illegal dumping.
3. Permit Year 3

4. Develop and
distribute fliers for
chemical awareness.
4. Permit Year 4

5. Develop and
distribute fliers for
proper waste disposal.
5. Permit Year 5

4. Public Event Outreach
Provide stormwater educational
information to the general public
at community events.

COVID-19 has limited outreach
opportunities at public events due
to their cancelation in 2020. As
such, alternative ways for this
type of outreach will be
necessary. Alternatives such as
booths at farmers markets and/or
a booth inside the library (if open)
can provide these opportunities
while still being safe for
participants.
1. The City of Conover
“Stormwater Advisory
Board” hears items, as
well as provides a
venue for the public to
ask questions related
to Stormwater. The
advisory board will
meet at minimum once
a year – but citizens
can also request a
meeting on an “as
needed” basis. Topics
discussed at advisory
board meetings shall
be recorded.
1. Annually

Permit Years 1-5

1. Number of advisory
board meetings held.

Number of attendees at
the advisory board
meetings.
2. Staff will have a
booth at the annual
“National Night Out”
event, Catawba
Riverfest, and/or
earth/arbor day events
to disperse stormwater
outreach
materials/awareness
through the use of
interactive educational
games and activities.

At minimum, one of
the above annual
events shall be
attended by
stormwater staff for
outreach each year.
2. Annually;

Permit Years 1-5

2. Number of attendees
at outreach booth
during the chosen
event(s).

Number of events
attended.

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Table 13: Public Education and Outreach BMPs
3. Staff will provide
alternative outreach
opportunities if the
events listed in BMP
4.B.2 are canceled, or
as an additional
outreach supplement.
Such opportunities
include but are not
limited to: an outreach
booth at the Conover
Library, and/or an
outreach booth at
farmers markets, or
other events if they are
still available.
3. Annually

Permit Years 1-5
3. Number of attendees
at alternative outreach
booth(s)

5. Student/teacher outreach
Provide educational information
to students and teachers through
classroom, workshop, and hands-
on activities related to stormwater
BMPs.

COVID-19 has limited outreach
opportunities at schools and
teacher workshops due to school
closures in 2020. To supplement
this, a PowerPoint presentation
that can be shown digitally by
staff and/or provided to teachers
for classes will be created
1. Staff will provide in
class instruction and/or
stormwater
educational activities
to students that attend
Newton-Conover
Middle School.
1. Annually

Permit Years 1-5
1. Number of classes
and/or activities
provided;
Number of students
present at these
classes/activities.

2. Staff will conduct
stormwater related
workshops with
teachers.
2. Annually

Permit Years 1-5

2. Number of teacher
workshops provided;

Number of teachers
who attended.
6. Printed Materials
Staff will design and distribute
new printed materials for target
audiences to aid stormwater
education. Previously the City had
printed materials that focused on
pet waste and general stormwater
1. Staff will create
printed material for
local government
distribution addressing
stormwater best
practices.
1. Permit Year 1

1. Were new outreach
materials created? Yes,
No; Status.

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Table 13: Public Education and Outreach BMPs
awareness. New printed materials
will focus on additional topics not
previously covered (BMP 3).
2. Staff will distribute
printed materials at
events, school
presentations, and
have them on display
for public acquisition
in Government
buildings. The flyers
will also be hosted on
the WPCOG website
to enable digital access
to this resource.
2. See BMP 3

2. See BMP 3
7. Annual Water Quality Conference
Sponsor the Western Piedmont
Council of Governments and
Lenoir Rhyne University’s
Annual Water Quality Conference
to provide outreach and public
participation. Staff will conduct
the annual regional conference for
continued education targeting
local government officials,
municipal staff, local businesses,
educators, and the general public.
1. Provide one
presentation about one
of the six NPDES
Minimum Control
Measures at each
annual conference. A
different MCM will be
presented on each
year.
1. Annually

Permit Years 1-5

1. Number of attendees
at conference.
8. Evaluate Pollutants Sources and Audiences
1. Evaluate following
target pollutants:
litter, sediment, gray
water, fats, oils,
grease, animal
operations,
underground storage
tanks, super fund sites,
chemicals, illicit
discharges, illegal
dumping and improper
disposal of waste.
1. Annually

Permit Years 1-5

1. - 2. Number of
target pollutant
violations;

Were SWMP revisions
needed to address
target pollutants or
audiences. Yes, No;
Status

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Table 13: Public Education and Outreach BMPs
Evaluate the target pollutants
(litter, sediment, gray water, fats,
oils, grease, animal operations,
underground storage tanks, super
fund sites, chemicals, illicit
discharges, illegal dumping,
improper disposal of waste),
sources, and associated target
audiences (residents, businesses,
schools, construction activity,
commercial, farms, industrial,
development community, general
public, and municipal employees)
likely to have significant
stormwater impacts and why they
were selected. This evaluation is
looking at target audiences that
are creating pollution to allow the
City to correctly focus education
efforts in those area.

2. Evaluate the
following target
audiences: residents,
businesses, schools,
construction activity,
commercial, farms,
industrial,
development
community, general
public and municipal
employees.
2. Annually

Permit Years 1-5

9. Evaluate Public Education and Outreach BMPs.
Evaluate the successful
components of outreach through
interest and feedback.
1. See BMP 17 1. See BMP 17 1. See BMP 17
Permit
Ref.
2.1.7 and 3.2.3: Web Site
Measures to provide a web site designed to convey the program’s message and provide online materials
including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory
mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
10. Website
1. Update and maintain
a stormwater web page
for the existing
municipal website.
1. Annually

Permit Years 1-5

1. Did the website
need revisions Yes,
No; Status.

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Table 13: Public Education and Outreach BMPs
Update and maintain the existing
stormwater web page on the City
of Conover website. The City
webpage will convey the
importance of water quality and a
link to the WPCOG Stormwater
webpage will be placed on the
Cities website. The WPCOG
Stormwater webpage will provide
educational resource links, list the
compliant procedures, stormwater
regulations, stormwater permit
information and good
housekeeping information.
Per the MS4 Audit, the existing
website will be expanded to
further detail outreach efforts,
provide more mechanisms for
reporting or providing input, the
most recent SWMP, each years
current annual report, and
ordinance will be put on the Cities
website for public availability.

2. WPCOG staff will
maintain and update
the WPCOG
stormwater web page
by: verifying all links
and contact
information are
current/active, and
posting educational
materials.

The municipal
stormwater webpage
will also have the
current SWMP,
stormwater ordinance,
and annual assessment
posted.
2. Annually

Permit Years 1-5

2. Was annual self-
assessment uploaded
to the Cities website?
Yes, no; Status;

Did links, contact
information, or
stormwater documents
need to be updated on
the WPCOG website
and/or the City of
Conover website? Yes,
No; Status;

Were new/current
educational materials
added to the WPCOG
website? Yes, No;
Status.

3. Set a hit counter in
order to record
engagement.
3. Annually

Permit Years 1-5
3. Report the number
of hits.
11. Education Regarding Illicit Discharges
Provide educational information
to municipal employees,
businesses, citizens and schools
about the hazards associated with
illicit discharges, illegal
dumping, and improper disposal
of waste.

1. Train municipal
employees in illicit
discharge detection
and elimination.
1. See BMP 49

1. See BMP 49
2. Distribute material
(generated from BMP
3) to target audiences
(municipal employees,
schools, businesses,
and citizens).
2. See BMP 3 2. See BMP 3
3. Provide education
during the enforcement
process.
3. Continuously,

Permit Years 1-5
3. Number of citizen
interactions during
enforcement.
Permit
Ref.
3.2.5: Stormwater Hotline
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
12. Hotline

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Table 13: Public Education and Outreach BMPs
The City of Conover will
continue to provide a stormwater
hotline, however it will be moved
to be the WPCOG stormwater
hotline. The hotlines uses will be
expanded to work as a way for
citizens to contact the City to
report illicit discharges,
stormwater/post construction
issues, outreach questions and
concerns, and MS4 related
concerns. Previously the hotline
was only utilized for IDDE or
stormwater violation reporting.

1. Update the specific
staff member who will
serve as the hotline
contact.
1. Permit Year 1

1. Was staff member
identified; Yes or No.
2. Update hotline
number for stormwater
complaints and
information should the
number change.
2. Annually

Permit Years 1-5

2. Did the hotline
number need to be
updated? Yes, No;
Status.
3. Record number and
type of complaints,
concerns and
information related to
each call.

Purpose of the call,
‘type’/measure the call
was about, date it
occurred, and
municipality of the
caller will be recorded
and used for
improvement on
outreach and the
hotline itself.
3. See BMP 12.B.5

3. See BMP 12.B.5

4. Train stormwater
hotline staff in general
stormwater awareness,
complaint call
protocols and
appropriate contacts
for referral and typical
stormwater issues.

4. Annually,

Permit Years 1-5

4. Did hotline staff
receive training? Yes,
No; Status.
5. Publicize contact
information on the
City and WPCOG
Stormwater webpages
as well as the City of
Conover Facebook
page.
5. Continuously,

Permit Years 1-5

5. Number of hotline
calls received overall.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 25

PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that
complies with applicable State, Tribal, and local public notice requirements. The City of Conover’s Planning Board will
continue to function as the City’s stormwater/watershed advisory board. The WPCOG Water Resources Committee will
continue to offer a forum for public comment with input and representation from the City of Conover as a way to
represent their municipality/citizens in these meetings along with other municipalities. The Boards/Committee will also
help provide input and guidance on stormwater issues. The City has a community volunteer program to gain citizen
participation to complete stream clean-ups or litter sweeps. The City of Conover has an established hotline (main number
for the City Hall), but will now be directed to WPCOG stormwater hotline, as well as, the addition of a webpage reporting
form and survey/s, along with the use of the existing WPCOG Water Resource Committee to gather public input. All
events, programs, and public forums will be announced through social media and/or printed handouts. The City of
Conover will manage, implement, and report on the following public involvement and participation BMPs.

Table 14: Public Involvement and Participation BMPs
Permit
Ref.
3.3.1: Public Input
Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
13. Hotline for Public Input
Provide a mechanism for public
input on stormwater issues and
the stormwater program through
utilizing the stormwater hotline
(BMP 12).

Previously the City of Conover
stormwater hotline was primarily
used as a violation reporting tool.
Its use will be expanded to
encourage its use as a public input
tool as well.
1. Stormwater hotline
(BMP 12) shall
include a public input
component and/or
record public input
comments/concerns.
1. See BMP 12

1. See BMP 12
14. Web based form reporting
Provide an online form for public
input and stormwater reporting
via the WPCOG website this will
create an additional way for
citizens to report issues and
1. Establish a web
based email complaint/
reporting/input tool to
be housed on the
WPCOG website.
1. Permit Year 1

1. Form established –
Yes or No; Status.

Date form was
established.

DRAFT NCS000431 SWMP
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Table 14: Public Involvement and Participation BMPs
concerns, as well as have input on
the stormwater program.

City of Conover Public Works
already has a general reporting
tool in place that receives
stormwater reports from the
general public. Stormwater issues
reported via the public works tool
will be responded too and
documented the same as the
WPCOG online reporting form to
ensure all reported
issues/concerns are addressed.
2. Use the form to
record and track
responses, inputs,
issues, and concerns
for metric reporting.

Purpose of each
question, report, or
comment will be
recorded
2. Continuous,
following the
establishment of the
form in Permit Year 1.

Permit Years 2-5

2. Number of
questions, reports, and
comments submitted
via the form

3. Maintain the web
based
complaint/reporting/in
put form on the
WPCOG website.
3. Continuous,
following the
establishment of
Permit Year 1.

Permit Years 1-5

3. Did the web form
require revisions? Yes,
No; Status.
15. Social Media Outreach – Event Promotion
Utilize the existing City of
Conover Facebook and Twitter
pages to promote stormwater
events, projects, outreach/general
stormwater awareness, and
stormwater programs. This will be
used as an outreach tool to
provide exposure to a larger
audience and encourage
engagement from the general
public.
1. Utilize the existing
City of Conover
Facebook and Twitter
page to promote public
involvement and
participation related to
stormwater programs,
events, and projects.

The social media
pages will also be used
to post stormwater
educational materials
and provided general
stormwater awareness.
1. Continuously

Permit Years 1-5

1. Total Number of
posts on the City of
Conover Facebook
page related to the
stormwater program.

Total Number of posts
on the City of Conover
Twitter page related to
the stormwater
program.
16. Water Resources Committee
Provide a mechanism for public
input and participation via
regional meetings on stormwater
issues and the stormwater
program. Typically, this
committee is hosted by the
WPCOG once a quarter. This
committee also encourages
municipal interconnectivity
regarding water quality within the
region.
1. Participate in
quarterly Water
Resource Committee
meetings, which are
open to the public, for
discussion of water
quality issues within
the region.

Topics discussed will
be recorded for annual
reporting.
1. Quarterly meetings

Permit Years 1-5

1. Number of attendees
at each meeting.

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Table 14: Public Involvement and Participation BMPs
2. Hold annual
Stormwater Advisory
Board meetings, open
to the public, for
participation in
discussion related to
stormwater issues.

The board shall meet
at minimum annually,
citizens can also
request an advisory
board meeting in
addition to the annual
meeting.
2. See BMP 4.1

2. See BMP 4.1
17. Public Survey and Evaluation
Provide a mechanism for public
input by creating a survey to
engage the public and gauge
public interest in stormwater
issues and the stormwater
program. The survey will be
taking in responses/input on the
program as a whole – covering
each minimum measure and BMP
that refers to this Survey.
1. Create and
administer an annual
survey to be housed on
the WPCOG
stormwater website
once a year, open to
feedback for a total of
4 weeks. The survey
will also be linked on
the City of Conover
website and social
media pages.

Responses/results of
the survey will be
analyzed for reporting
and evaluation.
1. Annually

Permit Years 1-5

1. Number of surveys
completed.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
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Table 14: Public Involvement and Participation BMPs
Permit
Ref.
3.3.2: Volunteer Opportunities
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
18. Stream Cleanup Events
Provide volunteer opportunities
for ongoing citizen participation
through stream cleanup or litter
sweep activities.

1. Hold stream cleanup
efforts by engaging
groups to conduct
stream cleanup
activities in
appropriate areas. The
events will be
promoted by the City
and WPCOG.

For the City of
Conover the stream
cleanups will focus on
Henry Fork, Jacob
Fork, Clark Creek,
and/or water bodies
that feed into them to
help improve water
quality and provide
personal awareness for
participants.
1. Annually

Permit Years 1-5

1. Number of stream
cleanup events held;

Number of stream
cleanup participants
total;

Number of trash bags
filled.
2. Provide all materials
for stream cleanup
activities (i.e. gloves,
trash bags, and trash
pickers) hosted by the
City and WPCOG.
2. Annually

Permit Years 1-5

2. Number of stream
clean up materials
distributed.

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Table 14: Public Involvement and Participation BMPs
3. The City and
WPCOG will publicize
the event (hosted by
WPCOG) to the public
to gather volunteers
for stream cleanup
efforts to assist in
public awareness and
involvement. The
event will be posted on
the WPCOG website,
The City of Conover
website, and flyers will
be distributed at City
Hall.
3. Annually

Permit Years 1-5

3. Was the event
publicized? Yes, No;
Status;

Number of participants
per event.

DRAFT NCS000431 SWMP
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PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
Per the MS4 Inspection Report the City has written procedures for implementing an IDDE Program. To increase efforts
the City will locate priority areas likely to have illicit discharges, conduct routine dry weather outfall inspections, identify
illicit discharges and trace sources, eliminate the source(s) of an illicit discharge, and evaluate and assess the IDDE
Program.
The City has a stormwater ordinance and other regulatory mechanisms that provide the legal authority to prohibit illicit
connections and discharges to the MS4, as well as the authority to apply enforcement to violators of the ordinance. The
documents will be reviewed, and if necessary, updated to maintain the program and enforce IDDE issues effectively.
The City of Conover has approximately half of the MS4 mapping completed; however as development occurs the map
and associated components will be updated accordingly.
In the last permit cycle the City did not conduct dry weather screening or maintain written procedures for dry weather
field activity (II.D.2.d. Dry Weather Flow Program). Within the Stormwater Management Plan a schedule is to be created
to conduct dry weather screening annually. Data such as date screening occurred, location of inspected outfall, and photos
of outfall will be recorded in GIS.
The City of Conover in the past has investigated IDDE complaints; however there is no tracking mechanism for
documenting violations and enforcement actions (II.D.2.j.). Within the new permit cycle, the use of a GIS application to
track and document IDDE cases will be used. This will allow the City to identify priority areas based on historical data.
Further, the City will continue to train municipal staff and the general public to identify illicit discharges and illegal
dumping through the use of educational outreach materials and training opportunities. Educational material will be
available to help educate public employees, businesses, and the general public about hazards associated with illicit
discharges and the improper disposal of waste.
Public complaints of any kind could be submitted to the City through point contact on the webpage. A webpage portal
will be established on the WPCOG website, as well as, linked to on the City website. The portal will be publicized, as
well as, the stormwater hotline phone number, as mentioned in the public education and outreach and public involvement
sections of this plan. A citizen can make a complaint via hotline number or through an email tool on the WPCOG
webpage.
The City of Conover will develop, manage, implement, document, report, and enforce an Illicit Discharge Detection and
Elimination Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs.
The existing Illicit Discharge Detection and Elimination Program will be expanded in order to implement a complete
program by permit year 5.

Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
Ref.
3.4.1: MS4 Map
Measures to develop, update and maintain a municipal storm sewer system map including stormwater
conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
19. Continual Updates to MS4 map

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Table 15: Illicit Discharge Detection and Elimination BMPs
Major outfalls will be identified
and numbered, flow direction and
receiving waters will be added.
The existing MS4 map has
outfalls throughout the City
already marked, however they
will be numbered and major
outfalls will be separated/marked.
The majority of the permitted
MS4 area has been mapped,
however some neighborhoods and
industrial outfalls have not yet
been mapped. These specific
areas will be defined and added
into the MS4 map to ensure full
coverage of the City. Map at least
20% of unmapped areas each year
until all areas have been mapped
within the permit term
1. Add a layer
identifying/separating
major outfalls from all
outfalls. Number all
outfalls to provide
them with a form of
identification.
1. Permit Years 1-5

1. Report number of
major outfalls
identified;

Date layer was
finalized.
2. Add unmapped
areas within the MS4
and add/map the
stormwater features in
said areas to ensure
full coverage.
2. Permit Years 1-5 2. Number of Major
outfalls in newly
mapped area;

Were the map area
shortcomings mapped?
Yes, No; Status;

Date additional areas
were mapped.
3. Add flow directions
to the map as other
components are being
mapped/created.
3. Permit Years 1-5

3. Report when flow
directions are added.
4. Add new
infrastructure to the
MS4 map as new
construction occurs,
updated on an annual
basis.
4. Annually

Permit Years 1-5
4. Was new
infrastructure added to
the map: Yes, No;
Status.
Permit
Ref.
3.4.2: Regulatory Mechanism
Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to
prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4,
including enforcement procedures and actions.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
20. Maintain Legal Authority
1. Update the existing
IDDE ordinance to
follow the current
NCDEQ model
ordinance.
1. Permit Year 1 1. Was ordinance
updated? Yes, No;
Status;

Date ordinance was
updated to the current
model ordinance.

DRAFT NCS000431 SWMP
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Table 15: Illicit Discharge Detection and Elimination BMPs
Review existing Ordinance
(Article VII. – Illicit Discharges
of City of Conover Code of
Ordinances) in order to maintain
the legal authority to prohibit,
detect, and eliminate illicit
connections and discharges,
illegal dumping and spills into the
MS4, including enforcement
procedures and actions. Update
ordinance if required.

2. Review the
ordinance and update
if revision is required.
Revisions will require
council reapproval.
2. Annually

Permit Years 1-5

2. Were revisions to
the ordinance needed?
Yes, No; Status.
Permit
Ref.
3.4.3: IDDE Plan
Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal
dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4.
The plan shall provide standard procedures and documentation to:
a) Locate priority areas likely to have illicit discharges,
b) Conduct routine dry weather outfall inspections,
c) Identify illicit discharges and trace sources,
d) Eliminate the source(s) of an illicit discharge, and
e) Evaluate and assess the IDDE Program.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
21. IDDE Plan
Establish, maintain, and
implement a written IDDE Plan to
detect and address illicit
discharges, illegal dumping and
any non-stormwater discharges
identified as significant
contributors of pollutants to the
MS4.

Previously the City of Conover
had IDDE standard operating
procedures, this IDDE plan will
build upon those and better define
the procedures for previously
lacking elements such as but not
limited to: IDDE investigations,
1. Develop written
IDDE Plan to define
the procedures of
identifying, tracking
and processing illicit
discharges, illegal
dumping and
significant contributors
of pollutants to the
MS4. Submit IDDE
Plan to DEQ for
approval.
1. Permit Year 1

1. Was IDDE plan
developed? Yes, No;
Status;

Date draft plan is
submitted to DEQ for
approval.

2. Train staff on the
processes defined in
the IDDE Plan and
what is required by the
IDDE ordinance.
2. See BMP 49

2. See BMP 49

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Table 15: Illicit Discharge Detection and Elimination BMPs
facility inspections, and dry
weather screening.

The IDDE plan will have a focus
on documentation of IDDE
investigations and procedures for
how the City shall handle IDDE
cases/issues including the
response the city shall take in
response to IDDE reports.
3. Implement/Enforce
the IDDE Plan and
IDDE Ordinance.
3. See BMP 26

3. See BMP 26
22. Location of Priority Areas
Establish and maintain procedures
for locating priority areas likely to
have illicit discharges. A high
priority area is an area that has a
high chance of stormwater
pollution potential: Areas with
known dry weather outfall
flows/violations, repeat offenders,
business/commercial areas,
industrial areas, and businesses
with high pollution potential.
1. Use MS4 map to
locate outfalls near
high pollution risk
areas. The priority
areas will be re-
evaluated on an annual
basis.

1. Annually,

Permit Years 1-5

1. Were priority areas
located? Yes, No;
Status.

2. Review priority
areas to determine if
additional areas need
to be included as
priority areas. The
priority areas will be
re-evaluated on an
annual basis.
2. Annually,

Permit Years 1-5

2. Were additional
priority areas
determined? Yes, No;
Status;

Number of Priority
areas added upon
revision.
23. Dry Weather Outfall
Inspections

Perform regular dry weather (no
rain in previous 72 hours) outfall
inspections to proactively identify
illicit discharges and illicit
connections. The City will be
broken into 5 sections, with at
least one section (20%) being
inspected each permit year. If
additional outfalls are located,
1. Establish a
procedure to divide the
City and create a
schedule for dry
weather inspections for
known outfalls. The
procedures will be
defined by the City
IDDE plan (BMP 21).
1. Permit Year 1

1. Were dry weather
inspection procedures
and schedule
established Yes, No;
Status;

Date SOP and
schedule established.

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Table 15: Illicit Discharge Detection and Elimination BMPs
they will be included in further
dry weather
inspections/scheduling.
2. Implement dry
weather inspection
procedures.
Date inspections
occurred, location of
inspected outfall, and
photos of outfall will
be documented.
2. Annually,

Permit Years 2-5

2. Number of dry
weather inspections
completed;

Number of potential
illicit discharges (from
dry weather flow)
identified.
24. Illicit Discharges and Trace Sources
Establish procedures to track and
document Illicit Discharge
investigations. The procedures
will be defined by the municipal
IDDE plan (BMP 22).
1. Establish procedures
to track verified
discharges and trace
sources.
1. See BMP 26

1. See BMP 26
2. Maintain illicit
discharge tracking
documentation.
2. See BMP 26

2. See BMP 26
25. Maintain and Implement IDDE Plan
Maintain and implement the
IDDE Plan to detect and address
illicit discharges, illegal dumping
and any non-stormwater
discharges identified as
significant contributors of
pollutants to the MS4.
1. Inspect priority
areas likely to have
illicit discharges on a
semi-annual basis and
reported incidents
received (BMP 22).
1. Continuously,

Permit Years 1-5

1. Number of illicit
discharges found in
priority areas.

2. Investigate and
enforce
reported/identified
IDDE issues.

SOP’s for follow up
inspections and date of
IDDE case closures
will be included in the
IDDE plan.
2. See BMP 26

2. See BMP 26

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Table 15: Illicit Discharge Detection and Elimination BMPs
3. Evaluate and assess
the IDDE
plan/program –
Identify where
improvements can be
made based on data
collected.

Major changes must be
approved by DEQ
from the previously
approved IDDE Plan.
3. Annually

Permit Years 1-5

3. Were revisions to
the IDDE plan
needed? Yes, No;
Status.

Permit
Ref.
3.4.4: IDDE Tracking
Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was
observed, the results of the investigation, any follow-up of the investigation, the date the investigation was
closed, the issuance of enforcement actions, and the ability to identify chronic violators.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
26. IDDE Tracking
Staff will update and maintain
the mechanisms for tracking and
documenting the date(s) an illicit
discharge, illicit connection or
illegal dumping was observed,
the results of the investigation,
any follow-up of the
investigation, the date the
investigation was closed, the
issuance of enforcement actions,
and identifying chronic violators.
1. Develop and Utilize
an online GIS map
layer for tracking
IDDE violations,
recording who made
the complaint, location
of complaint, note
prior IDDE violations,
status of the
investigation and
actions taken.
1. Permit Year 1

1. Was the IDDE map
layer created? Yes,
No; Status;

Date IDDE map
developed.

2. Track illicit
discharge/connection
and illegal dumping
reports/investigations
utilizing the IDDE
layer on top of the
MS4 map.

Differentiate staff
discovery from citizen
reporting to allow for
review of outreach
program.
2. Continuously,

Permit Years 1-5

2. Number of verified
IDDE issues.

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Table 15: Illicit Discharge Detection and Elimination BMPs
3. Upon investigation,
enforce Illicit
Discharge/connection
and Illegal Dumping
violations to ensure the
responsible
party/violator remedies
verified illicit
discharges.
3. Continuously,

Permit Years 1-5

3. Number of
violations/enforcement
actions issued;

Number of
violations/enforcement
actions resolved.
4. Establish and
maintain a list of
chronic violators, as
applicable. Updated on
a Semi-annual basis.
4. Semi-Annually,

Permit Years 1-5

4. Number of chronic
violators identified.
5. Evaluate and assess
the IDDE tracking
map layer – Identify
where improvement
can be made based on
data collected,
problems encountered
and needs. Evaluation
of the map will be
done on an annual
basis to find
shortcomings with the
IDDE program should
they be determined.
5. Annually,

Permit Years 2-5

5. Were revisions to
the IDDE map
needed? Yes, No;
Status.
Permit
Ref.
3.4.5: Staff IDDE Training
Measures to provide training for municipal staff and contractors who, as part of their normal job
responsibilities, may come into contact with or otherwise observe an illicit discharge, illicit connection or
illegal dumping. Training shall include identifying and reporting illicit discharges, illicit connections and
illegal dumping. Each staff training event shall be documented, including the agenda/materials, date, and
number of staff participating.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
27. Staff Training
Train municipal staff and
contractors to identify and report
illicit discharges, illicit
connections, illegal dumping and
spills.
1. Identify staff
members and/or
contractors that are
likely to observe an
illicit discharge, illicit
connection and illegal
dumping.
1. See BMP 11

1. See BMP 11

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Table 15: Illicit Discharge Detection and Elimination BMPs
2. Hold IDDE training
events to educate staff
and contractors in
identifying and
reporting illicit
discharges, illicit
connections, illegal
dumping, and spills.
Trainings will have a
sign in sheet to track
the names of trained
individuals.
2. See BMP 49

2. See BMP 49
28. IDDE Educator
Establish appropriate staff
contacts for field inquiries
regarding IDDE education,
outreach and complaints. During
IDDE enforcement, an outreach
approach to raise awareness of
why the violation is problematic
will be taken (See BMP 11). The
hotline will also function as a
mechanic for responding to IDDE
questions from the public.
1. Train hotline
contacts in IDDE
awareness, complaint
call protocols, and
appropriate contacts
for referral.
1. See BMP 12 1. See BMP 12

2. Utilizing social
media and the City/
WPCOG webpages,
publicize contact
information for IDDE
reporting.
2. See BMP 12

2. See BMP 12

Permit
Ref.
3.4.6: IDDE Reporting
Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be
publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained
personnel.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
29. IDDE Reporting Hotline
Utilize the existing hotline to now
enable the public and municipal
employees to report illicit
discharges, illegal dumping, and
spills.
1. Utilize the hotline
(BMP 12) to receive
IDDE reports.
1. See BMP 12

1. See BMP 12

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Table 15: Illicit Discharge Detection and Elimination BMPs
2. Train hotline staff to
differentiate between
illicit discharge
complaints and
stormwater/post-
construction
complaints. The staff
will also be trained to
keep adequate records
of the calls for metrics.
2. See BMP 12

2. See BMP 12
3. Publicize Hotline by
including the phone
number on educational
materials. Post the
hotline number on the
City and WPCOG
websites and shared
via social media
accounts.
3. See BMP 12

3. See BMP 12
30. IDDE Reporting Web-based Reporting Form
Staff will provide a rapid response
to all complaints received. Staff
will record the response dates and
summary of results to improve
IDDE program and the online
Map..
1. Use web based
reporting form for
IDDE reporting.
1. See BMP 14

1. See BMP 14
31. IDDE Reporting Efficiency
Staff will provide a rapid response
to all complaints received. Staff
will record the response dates and
summary of results to improve
IDDE program and application.
1. Use the online GIS
map, once established
(BMP 19), to track
time of complaint, site
visit, type of complaint
and all
enforcement/resolution
measures.
1. See BMP 19

1. See BMP 19

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Table 15: Illicit Discharge Detection and Elimination BMPs
2. Evaluate response
time. Work to
minimize response
time to reported issues
and record what is
causing those issues to
be fixed in later
iterations of the plan.
Track the times
elapsed between when
an IDDE incident is
reported, and when it
is addressed.
2. Annually,

Permit Years 1-5

2. Average response
time.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 40

PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the City of Conover relies upon the North Carolina Sedimentation Pollution
Control Act (SPCA) of 1973 and the NCG010000 permit for construction activities as qualifying alternative programs to
meet the NPDES MS4 Permit requirements for all construction site runoff control measures to reduce pollutants in
stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre and any
construction activity that is part of a larger common plan of development that would disturb one acre or more.

Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Permit
Reference State or Local Program Name Legal
Authority Implementing Entity
Meets Whole
or Part of
Requirement
3.5.1 -
3.5.4
Catawba County Delegated SPCA
Program*
15A NCAC
Chapter 04,
Inter-local
Agreement for
Enforcement
Services of
Catawba
County Soil
Erosion and
Sediment
Control
Ordinance
Catawba County Whole
*The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at:
https://library.municode.com/nc/catawba_county/codes/code_of_ordinances?nodeId=COOR_CH31SOERSECO

In addition to the delegated SPCA Program, opportunities for public input through the stormwater hotline, web-page
reporting tool and additional waste management requirements for construction site operators provide a comprehensive
construction site run off control program. The City of Conover will also implement the following BMPs to meet NPDES
MS4 Permit requirements.

Table 17: Construction Site Runoff Control BMPs
Permit
Ref.
3.5.6: Public Input
Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
32. Municipal Staff Training

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 41

Table 17: Construction Site Runoff Control BMPs
Train municipal staff who receive
calls from the public on the
protocols for referral and tracking
of construction site runoff control
complaints.
1. Train municipal
staff on proper
handling of
construction site runoff
control complaints.
1. See BMP 49 1. See BMP 49
33. Means of Public Input

Utilize the survey, the hotline,
and the online form to give
citizens methods of responding to
how construction runoff is being
managed. The survey will ask
questions regarding: how they
view construction runoff in the
City, what they think should be
changed to improve upon said
problems, and where they believe
there should be more focus within
the program.
1. Use survey (BMP
17) to obtain feedback
about public
perspective about
construction runoff in
the City.
1. See BMP 17

1. See BMP 17
2. Administer the
survey to allow for
input on construction
runoff in the City. The
survey will be linked
to on the WPCOG
stormwater webpage
and the City of
Conover website.
2. See BMP 17

2. See BMP 17
3. Utilize reporting
form (BMP 14) that
will allow the public to
write concerns and
report construction
runoff issues.
3. See BMP 14

3. See BMP 14
4. Publicize the ability
to report concerns
about construction
runoff issues via the
online form on the
City and WPCOG
websites and social
media.
4. See BMP 14

4. See BMP 14

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 42

Table 17: Construction Site Runoff Control BMPs
Permit
Ref.
3.5.5: Waste Management
Measures to require construction site operators to control waste such as discarded building materials, concrete
truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to
water quality.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
34. Establish and Maintain Legal Authority of Construction Waste
Require construction site
operators to control waste at the
construction site that may cause
adverse impact to water quality.
1. Develop an
ordinance that
addresses construction
site waste.
1. Permit Year 1

1. Ordinance
developed: Yes or No,
Status.
2. Adopt developed
ordinance through
council approval.
2. Permit Year 1 2. Ordinance adopted;
Yes, No; Status.
3. Train municipal
staff on identifying
and reporting
construction waste
violations.
3. See BMP 49 3. See BMP 49
4. Maintain adopted
ordinance (if revisions
are needed).
4. Annually

Permit years 2-5

4. Were any revisions
to the waste
management ordinance
made? Yes, No;
Status.

5. Enforce ordinance
using the online GIS
map to track and
document
construction site
waste concerns and
corrective actions.
5. See BMP 19

5. See BMP 19.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 43

PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
The City of Conover SWMP 2013 has policy language for deed restrictions and protective covenants. In the new SWMP
permit cycle the language will also be included in the Stormwater Ordinance. An amendment to the ordinance will allow
the language to have legal significance.

Contracting WPCOG, an inventory of projects will be established (BMP 35.B.1, 2, and 3) for developments within the
municipal limits, this is in response to Permit Citation II.F.2.d, of the latest DEQ MS4 audit (2018). Along with the
inventory list, proactive inspections will be administered by Staff semi-annually and the owner of the privately owned
SCM will be required to have an inspection done by a certified private engineer annually to ensure SCM functionality
(Permit Citation II.F.2.g.). Upon non-compliance, enforcement action will be taken. The City will have a GIS tracking
mechanism to proactively enforce to obtain compliance (II.F.2.i.).

This SWMP identifies the minimum elements to develop, implement and enforce a program to address stormwater runoff
from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less
than one acre that are part of a larger common plan of development or sale, that are located within the City of Conover
and discharge into the MS4. These elements are designed to minimize water quality impacts utilizing a combination of
structural Stormwater Control Measures (SCMs) and/or non-structural BMPs appropriate for the community, and ensure
adequate long-term operation and maintenance of SCMs.

In accordance with 15A NCAC 02H .0153 and .1017, the City of Conover implements the following State post-
construction program requirements, which satisfy the NPDES Phase II MS4 post-construction site runoff control
requirements as Qualifying Alternative Program(s) (QAPs) in the MS4 area(s) where they are implemented.

Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program
State QAP Name State Requirements Local Ordinance / Regulatory
Mechanism Reference
Water Supply Watershed (WS-IV) 15A NCAC 2B
.0620 - .0624
WS-IV Watershed Ordinance (See
map) Protected Areas

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 44

The City of Conover has a small portion on the east side of the City limits located within a water supply watershed. The
area within the watershed boundaries are required to follow those rules to ensure drinking water quality is being
maintained. This is known as a Qualifying Alternative Program (QAP). The City is also subject to the NPDES Phase II
MS4 post-construction program requirements. These existing requirements will be codified in local ordinance(s) per
BMP 37.B.1 and implementation per BMP 37.B.3-4.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 45

Table 19: Summary of Existing Post-Construction Program Elements

Permit Requirements for Plan Review
and Approval
Municipal Ordinance/Code Reference(s) and/or
Document Title(s) Date Adopted
3.6.2(a) Authority Appendix C - Stormwater Ordinance (Phase II) Section
10.2 May 7, 2007
3.6.3(a) & 15A NCAC 02H.0153(c)
Federal, State & Local Projects
Appendix C - Stormwater Ordinance (Phase II) Article
II May 7, 2007
3.6.3(b) Plan Review Appendix C - Stormwater Ordinance (Phase II) 30.2 May 7, 2007
3.6.3(c) O&M Agreement Appendix C - Stormwater Ordinance (Phase II) 50.2 May 7, 2007
3.6.3(d) O&M Plan Appendix C - Stormwater Ordinance (Phase II) 50.2 May 7, 2007
3.6.3(e) Deed Restrictions/Covenants Appendix C - Stormwater Ordinance (Phase II) 40.2
and 40.3 May 7, 2007
3.6.3(f) Access Easements Appendix C - Stormwater Ordinance (Phase II) 50.8 May 7, 2007
Permit Requirements for Inspections
and Enforcement
Municipal Ordinance/Code Reference(s) and/or
Document Title(s) Date Adopted
3.6.2(b) Documentation Appendix C - Stormwater Ordinance (Phase II) 50.1 May 7, 2007
3.6.2(c) Right of Entry Appendix C - Stormwater Ordinance (Phase II) 50.2 May 7, 2007
3.6.4(a) Pre-CO Inspections Appendix C - Stormwater Ordinance (Phase II) 30.3 May 7, 2007
3.6.4(b) Compliance with Plans Appendix C - Stormwater Ordinance (Phase II) 30.3 May 7, 2007
3.6.4(c) Annual SCM Inspections Appendix C - Stormwater Ordinance (Phase II) 50.3 May 7, 2007
3.6.4(d) Low Density Inspections Appendix C - Stormwater Ordinance (Phase II) 40.2 May 7, 2007
3.6.4(e) Qualified Professional Appendix C - Stormwater Ordinance (Phase II) 50.1 May 7, 2007
Permit Requirements for Fecal
Coliform Reduction
Municipal Ordinance/Code Reference(s) and/or
Document Title(s) Date Adopted
3.6.6(a) Pet Waste City Code Section 16-11 March 5, 1973
3.6.6(b) On-Site Domestic Wastewater
Treatment City Code Section 22-60 July 1, 2013

The post construction stormwater ordinance was adopted in 05.07.2007. It is noted that a new model ordinance has been
endorsed by the State. The City of Conover will be adopting the State’s template ordinance within Year One of the
NPDES permit cycle. The section numbers above are subject to change. This will be in addition to the States’ new model
watershed ordinance.

The annual reporting metrics for the post construction program are provided in Table 20: Post Construction Site Runoff
Control BMPs below.

Table 20: Post Construction Site Runoff Control BMPs
Permit
Ref.
4.1.3: Minimum Post-Construction Reporting Requirements
Measures to document activities over the course of the fiscal year (July 1 – June 30) including appropriate
information to accurately describe progress, status, and results.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
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Table 20: Post Construction Site Runoff Control BMPs
35. Standard Reporting
Implement standardized tracking,
documentation, inspections, and
reporting mechanisms to compile
appropriate data for the annual
self-assessment process. Data
shall be provided for each Post-
Construction/ Qualifying
Alternative Program being
implemented as listed in Tables
18 and 19.
1. Track number of
low density and high
density plan reviews
performed.
1. Continuously 1. Number of plan
reviews performed for
low density and high
density.
2. Track number of
low density and high
density plans
approved.
2. Continuously 2. Number of plan
approvals issued for
low density and high
density.
3. Maintain a current
inventory of low
density projects and
constructed SCMs
including SCM type or
low density acreage,
location and last
inspection date.
3. Continuously 3. Summary of number
and type of SCMs
added to the inventory;
and number and
acreage of low density
projects constructed.
4. Track number of
SCM inspections
performed.
4. Continuously 4. Number of SCM
inspections.
5. Track number of
low density
inspections performed.
5. Continuously 5. Number of low
density inspections.
6. Track number and
type of enforcement
actions taken.
6. Continuously 6. Number and type of
enforcement actions
taken.
Permit
Ref.
2.3 and 3.6: Qualifying Alternative Program(s)
Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state program
requirements.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
36. Qualifying Alternative Program
This permit requirement is fully met by the existing post-construction program, see references provided in
Table 19.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 47

Table 20: Post Construction Site Runoff Control BMPs
Permit
Ref.
3.6.2: Legal Authority
Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review
designs and proposals for new development and redevelopment to determine whether adequate stormwater
control measures will be installed, implemented, and maintained, (b) request information such as stormwater
plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance
with the Post-Construction Stormwater Management Program, and (c) enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater
discharges to determine whether there is compliance with the Post-Construction Stormwater Management
Program.
MP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
37. Phase II Post-construction Stormwater Ordinance
The City has adopted and will
maintain in effect the Phase II
Stormwater Ordinance, which
gives the City legal authority to
review designs for new
development and redevelopment,
to ensure adequate stormwater
controls, to request information,
to perform inspections on private
property, and to perform other
compliance activities related to
this measure.

The in-place ordinance will be
revised in the first permit year to
follow the NCDEQ model
ordinance.

The ordinance references the
DEQ BMP Design Manual as the
source of standards to be used in
selecting, designing, evaluating,
and maintaining structural and
non-structural BMPs.
1. Update the existing
stormwater ordinance
to follow the current
Phase II Stormwater
Model Ordinance
provided by NCDEQ.
1. Permit year 1 1. Was stormwater
ordinance revised?
Yes, no; Status;

Date ordinance was
revised.
2. Train staff (field
and office) in
Stormwater Ordinance
procedures and
enforcement actions.
2. See BMP 49

2. See BMP 49
3. Enforcement of the
Phase II Post-
construction
Stormwater Ordinance
to ensure compliance.
Should the correct
processes and order
not be followed, a
notice of violation will
be issued to address
the violation.
3. Continuously,

Permit Years 1-5

3. Number of notices
of violations issued;

Number of Civil
Citations issued;

Number of still in
progress of abatement
at time of annual
report.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 48

Table 20: Post Construction Site Runoff Control BMPs
Permit
Ref.
3.6.3: Plan Review and Approval
Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal,
State, and local government projects to comply with Post-Construction Program requirements throughout the
entire MS4 permitted area, unless the entity is subject to its own NPDES MS4 permit or a qualifying alternative
program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than
or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of
development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that
apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that
complies with 15A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan
that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and
protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure
that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A
NCAC 02H 1050 (9) and (10).
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
38. Plan Review and Approval
Review plans for all new
development and redevelopment
sites that will 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).

All required submittals (as
defined by the plan review
procedures) must be received by
the reviewer before the issuance
of a Certificate of Occupancy (per
development). Should the
procedures not be followed, a
notice of violation and stop work
order will be issued in accordance
with the City ordinance and SOP.

The City of Conover issues their
own certificates of occupancy.
The CO is not issued until all
stormwater requirements
(designs, submittals, and
inspections) are satisfied and the
Stormwater Administrator
approves the issuance.
1. Review procedures
and submittal
documents annually to
determine if items need
to be added or
modified.
1. Annually,

Permit Years 1-5

1. Were changes to the
procedures/submittal
documents needed?
Yes, No; Status.
2. Review plans for all
new development and
redevelopment sites
that will disturb greater
than or equal to one
acre. This is including
projects less than one
acre that are part of a
larger common plan of
development or sale.
This requirement also
applies to Federal, State
and Local Government
projects.

The City holds the
ability to have local
engineering firms
review stormwater
SCM designs on an as-
needed basis.
2. See BMP 35

2. See BMP 35

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 49

Table 20: Post Construction Site Runoff Control BMPs
3. Maintain the existing
SCM Inventory sheet.
Said sheet tracks all
required submittals,
relevant information,
and all projects within
the City that have gone
through (and/or are
going through) the
stormwater review
procedure.
3. See BMP 35

3. See BMP 35
39. Operation and Maintenance Agreement and Plan
The Operation and Maintenance
(O&M) agreement require owners
of structural SCM’s to perpetually
maintain and operate according to
the O&M plan submitted during
the plan review process, and
require submission of annual
inspection reports written by a
qualified professional.
1. Ensure that each
project has an approved
O&M Agreement and
O&M Plan prior to CO,
to be included in the
project checklist and
required prior to CO.
Each O&M agreement
will include a
requirement for annual
inspections.

1. Continuous

Permit Years 1-5

1. Number of
permitted projects
with O&M plans that
received their CO.
40. Recordation
The plan review process shall
include verification that
permanent legal mechanisms are
in effect ensuring the project is
built consistently with its
approved plans. This will be
verified through the submittal of
an engineer’s certification and
providing an as-built. These must
be received and accepted to
approve the issuance of that
projects CO.

A recorded deed restriction or
protective covenant, along with
an access easement is established
through recordation. Recording
both the access easement and
deed restrictions are required for
the issuance of a Certificate of
Occupancy.
1. Ensure each project
has recorded deed
restrictions and
protective covenants in
effect to ensure
development activities
will be maintained
consistent with the
approved plans (low
and high density
projects).
1. See BMP 35 1. See BMP 35

2. Ensure that each
SCM and associated
maintenance access
areas are recorded in a
permanent easement to
guarantee access for
inspection and
maintenance of the
SCM.
2. See BMP 35

2. See BMP 35

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 50

Table 20: Post Construction Site Runoff Control BMPs
Permit
Ref.
3.6.4: Inspections and Enforcement
Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post-
construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy.
Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s),
(b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual
inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance
Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require
that inspections be conducted by a qualified professional.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
41. Inspection and Enforcement
After project completion, but
prior to issuance of a certificate of
occupancy, an inspection will be
completed by a qualified
professional to ensure the project
has been constructed according to
the plan/design. Following
approval, annual inspections by a
qualified professional will be
completed. Low density projects
will be inspected once in a permit
term to watch for potential
unpermitted expansion and apply
enforcement if violations are
found.

1. Prior to issuance of a
CO, a qualified City
representative shall
perform an inspection
on all project SCMs to
ensure compliance. If
corrections are
required, then follow
up inspections will be
performed until the
SCM and project site is
compliant prior to the
issuance of CO.
1. Continuously

Permit Years 1-5

1. Number of pre-CO
inspections completed;

Number of repeat
inspections required.
2. Staff will perform
inspections of all SCMs
(both government and
non-government)
within the City on an
annual basis.
2. Annually,

Permit Year 1-5

2. Number of SCM
inspections completed;

Number of failed
SCM inspections.
3. Owner shall have a
Qualified Licensed
Professional perform an
SCM inspection in
accordance with the
O&M Agreement and
DEQ SCM manuals
once a year.
3. Annually

Permit Year 1-5

3. Number of qualified
licensed professional
inspections completed
with documentation
received.

Number of SCMs
under annual
inspection
enforcement.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 51

Table 20: Post Construction Site Runoff Control BMPs
4. Conduct inspection
of
20% of low-density
projects each year (See
BMP 35 for inventory).
4. Annually

Permit Years 1-5

4. Number of low
density inspections
done; Number of low
density violators
found; Number of low
density enforcement
actions issued.
Permit
Ref.
3.6.5: Documentation
Measures to maintain adequate documentation and standardized inspection and tracking mechanisms to: (a)
Maintain an inventory of post-construction SCMs and low density projects, (b) Document, track and maintain
records of inspections and enforcement actions. Tracking shall include the ability to identify chronic violators,
and (c) Make available to developers all relevant ordinances, post-construction requirements, design standards,
checklists, and/or other materials.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
42. Documentation – Low Density
Ensure tracking and records are
maintained on low density
projects to ensure that upon
inspection, impervious overages
can be determined, and corrective
actions taken. Ensure
informational materials are
available on the WPCOG website
to guarantee accessibility outside
of office hours. Through tracking
and inspections chronic violators
will be identified. 20% of the low
density sites will be inspected per
year.
1. Create and Maintain
a low density project
inventory. The
inventory will be
created by using the
existing zoning permit
inventory to see which
sites required a
stormwater review
previously.
1. See BMP 35

1. See BMP 35.
2. Inspect the
completed low-density
projects to ensure the
projects have not
expanded into a high
density classification
thus needing a SCM.
2. See BMP 41

2. See BMP 41

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 52

Table 20: Post Construction Site Runoff Control BMPs
3. Provide educational
material to the general
public about low
density developments:
during the issuance of
zoning permits,
distributed through
mailings, posted on
social media, and
handed out at events.

3. Continuously

Permit Years 1-5

3. Number of low
density educational
materials distributed.
43. Documentation – High Density
Ensure tracking and records are
maintained on projects to ensure
that upon granting of final CO
and follow-up inspection
impervious overages can be
determined and corrective actions
taken. Ensure informational
materials are available to
guarantee accessibility outside of
office hours. Through tracking
and inspections, chronic violators
will be identified.
1. Create and maintain
an inventory of all
developments and
redevelopments
(public and private)
with SCMs. Update
inventory as projects
are reviewed,
approved, and
constructed. The
inventory will be
created by using the
existing zoning permit
inventory to see which
sites required a
stormwater review
previously.
1. See BMP 35

1. See BMP 35

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 53

Table 20: Post Construction Site Runoff Control BMPs
2. Provide educational
material to developers
about high density
development. At a
minimum, hyperlinks
will be maintained on
the City webpage
directed to the
Ordinance and to the
BMP Design Manual.
Printed materials will
be distributed (but not
limited to): during the
issuance of zoning
permits, distributed
through mail, digitally
posted on social
media, and handed out
at events.
2. Continuously,

Permit Years 1-5

2. Number of high
density informational
materials distributed.
3. Establish links to all
ordinances, manuals,
policies, checklists,
design standards,
and/or other materials
on the WPCOG
website.
3. Annually

Permit Years 1-5

3. Items placed on the
webpage: Yes or No,
Status;

Were items replaced
with current versions
if revisions were
required? Yes, No;
Status.
Permit
Ref.
3.6.6: Fecal Coliform Reduction
Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H
.1017(7). At a minimum, the program shall include: (a) A pet waste management component, which may be
achieved by revising an existing litter ordinance, and (b) An on-site domestic wastewater treatment system
component, if applicable, which may be coordinated with local county health department, to ensure proper
operation and maintenance of such systems.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
44. Fecal Coliform Reduction

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 54

Table 20: Post Construction Site Runoff Control BMPs
Protective measures will be
established through the adoption of
the pet waste component of the
Phase II Stormwater Model
Ordinance in permit year 1.

Almost all of the City of
Conover’s wastewater is managed
via a sewer system. Installation of
septic systems is discouraged by
the City, but is allowed should the
sewer not be connectable to their
property. Outside of those outlier
cases, the only septic tanks in the
MS4 area are remaining older
tanks which are inspected by the
County.

The larger concern from
wastewater fecal pollution comes
from unmaintained sewer
lines/sewer breaks. An outreach
approach will be taken to assist in
reducing this pollutant and raise
awareness of what impacts not
repairing/maintaining sewer lines
has on water quality.
1. Revision of the in-
place stormwater
ordinance to include
the authority to
enforce pet waste
violations.
1. See BMP 37

1. See BMP 37
2. Develop and
distribute educational
materials on the
impacts of
unmaintained
wastewater systems
have on water
quality. These flyers
will be used to raise
awareness of septic
wastewater pollution.
2. Continuously,

Permit Years 1-5

2. Number of
wastewater
educational materials
distributed.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 55

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS

This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City of Conover
municipal facilities and operations. Pollution prevention and good housekeeping is accomplished through the
implementation of seven required programs, which collectively address the ultimate goal of preventing or reducing
pollutant runoff from municipal operations such as park and open space maintenance, fleet and building maintenance, new
construction and land disturbances, and municipal storm sewer system maintenance.

Pollution prevention and good housekeeping for municipal operations includes the following programs:

1. Municipal Facilities Operation and Maintenance Program (O & M)
2. Spill Response Program
3. MS4 Operation and Maintenance Program
4. Municipal SCM Operation and Maintenance Program
5. Pesticide, Herbicide and Fertilizer Management Program
6. Vehicle and Equipment Cleaning Program
7. Pavement Management Program

The City of Conover will manage, implement and report the pollution prevention and good housekeeping BMPs as
specified in Table 21 below for each required program in response for the MS4 Audit inefficiencies. BMPs 45 and 46 will
require a written inventory of facilities and potential pollutants. Several of the BMPs below address street and parking lot
issues by developing, adopting, and maintaining procedures that focus on pollutant removal in these impervious areas,
along with, Setting schedules and requirements for street/parking lot sweeping (BMP 58), collecting litter/debris (BMP
59), working in collaboration with community outreach program and developing standard spill procedures (BMP 47).

The City of Conover uses a vac-truck to clean the storm sewer conveyance system. An O & M plan had not been created
and maintained at the time of the MS4 DEQ Audit. Permit Reference: 3.7.3, BMP’s 48-51 focus on the training,
inspection, and maintenance of said system.

Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
Ref.
3.7.1: Municipal Facilities Operation and Maintenance Program
Measures to manage facilities that are owned and operated by the permittee and have the potential for
generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities;
perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard
documentation; provide staff training on general stormwater awareness and implementing pollution prevention
and good housekeeping practices.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
45. Municipal Facilities Operation & Maintenance (O & M) Plan

DRAFT NCS000431 SWMP
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January 27, 2021
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Table 21: Pollution Prevention and Good Housekeeping BMPs
An O & M Plan must be
developed, implemented, and
maintained for each municipal
facility with the potential to
generate stormwater pollution.
These plans will define the
expectations of the facility in
regards to stormwater/MS4
regulations. Each municipal
facility in which this is applicable
will implement an O&M plan.
The implementation of a plan
entails signing a legally binding
document that defines the party
charged with ensuring that the
facility is correctly maintained
and documentation of the
maintenance is adequate. The
documents will also define the
procedures in how the facility will
be maintained to reduce the risk
of stormwater pollution. The
facilities requiring O&M plans
will be inventoried through BMP
46. Should the facility maintain
and/or store vehicles, washing
procedures will be defined in the
facilities O&M plan.
1. Inspect all
municipal facilities to
determine which
facilities require an
O&M plan to be
developed. All
facilities will be
inspected once per
permit term. High
pollution potential
facilities will be
inspected annually
(See BMP 46).
1. See BMP 46 1. See BMP 46
2. Develop a facility
specific O&M plan for
each municipal facility
with the potential to
generate stormwater
pollution. Each plan
will define required
procedures per
applicable facility to
inspect, maintain and
evaluate the facilities
risk of stormwater
pollution.
2. Permit Year 1

2. Number of facility
O&M plans
developed.
3. Implement the
written O&M Plan
(per applicable
facility).
3. Permit Year 1

3. Number of facility
O&M plans
implemented.
4. Enforce and inspect
the facilities to ensure
compliance with the
O&M Plans.
4. See BMP 46

4. See BMP 46
46. Municipal Facilities

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 57

Table 21: Pollution Prevention and Good Housekeeping BMPs
The municipal facilities operation
and maintenance plan will ensure
the facilities are being
managed/maintained in a way that
does not negatively impact water
quality. The facilities will be
maintained in a scheduled and
well-defined manner by
performing routine inspections. If
a facility is subject to SPCC
requirements, then specific
inspection procedures will be
completed per the SPCC
requirements.

As an inventory of municipally
owned facilities with stormwater
pollution potential already exists
(developed after the 2018 audit),
any new municipal facilities built
during the permit cycle will be
evaluated and added to the list
after the facilities completion.
1. Establish: standard
operating procedures
for municipal facility
inspections, a schedule
of inspections, and a
standard for report
documentation/trackin
g. These SOP’s will be
defined in each facility
O&M plan. The
procedures for
inspections will be
included in the City
IDDE plan.
1. Permit Year 1 1. Were procedures
established? Yes, No;
Status;

Date procedures
established;

Was an inspection
schedule established?

Date of schedule
establishment.

2. Verify/reevaluate
the pollution potential
of facilities from the
existing facility
inventory.
This will be done
during facility
inspections to
determine if the
facility has become, or
still is, a potential
source of pollution.
The inventory shall be
split between high
potential and low
potential facilities.
2. Annually

Permit Year 1-5

2. Number of facilities
added to the pollution
potential inventory.
3. Perform annual
facility inspections for
high stormwater
pollution potential
facilities and once per
permit term
inspections for low
potential facilities,
following the
inspection SOP’s
established in BMP
No. 46.1.
3. Annually

Permit Years 1-5

3. Number of facilities
inspected;

Number of SPCC
permitted facilities
inspected.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
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Table 21: Pollution Prevention and Good Housekeeping BMPs
4. Document and
correct issues found
during inspections. If
a facility is subject to
SPCC requirements,
then ensure the correct
documentation is in
place for compliance
with the
regulation/requirement
s.
4. Annually

Permit Years 1-5

4. Number of
corrective actions
taken
(SPCC permitted
facilities and non-
SPCC facilities).

5. Train municipal
facility staff on proper
stormwater awareness
and good
housekeeping
methods.

5. See BMP 49

5. See BMP 49
Permit
Ref.
3.7.2: Spill Response Program
Measures for facilities and operations that store and/or use materials that have the potential to contaminate
stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on
spill response procedures.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
47. Spill Response
1. Maintain the
existing spill response
procedures in response
to problems that may
arise from
implementation of spill
procedures.
1. Annually

Permit Years 1-5

1. Did spill response
procedures need to be
revised? Yes, No;
Status.
2. Train facility staff
on spill response
procedures.
2. See BMP 49

2. See BMP 49

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
Page 59

Table 21: Pollution Prevention and Good Housekeeping BMPs
Spill response program for
facilities and operations that store
and/or use materials that pose a
spill risk. The program will be
designed in a way that tracks
potential polluting facilities as
well as defining the
procedures/materials required for
spill response in those facilities.
The definition of reportable spills
will be written into each facility
spill response plans following
§143-215.85.
The updated spill response
procedures will be included in the
written IDDE plan. Currently they
focus primarily on public works
facilities with spill potential but
will be expanded to include more
facility specific procedures as
well.
3. Respond to spills as
they occur and manage
the spill/s following
established spill
procedures.

Reportable spills (per
§143-215.85) will be
reported to DEQ.
3. Continuously,

Permit Years 1-5

3. Number of non-
reportable spills;

Number of spills
reported to DEQ.

Permit
Ref.
3.7.3: MS4 Operation and Maintenance Program
Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation
and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections,
maintain the collection system including catch basins and conveyances; and establish specific frequencies,
schedules, and standard documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
48. MS4 Operation & Maintenance (O & M) Plan
An O & M Plan must be
developed, implemented and
maintained to follow the
requirements of the MS4 NPDES
Phase II Stormwater collection
system permit. As a component of
this plan, a capital improvement
component will be included to
assist in prioritizing parts of the
MS4 as determined by the MS4
inspections (BMP 50) The O&M
1. Develop an O&M
plan to define the
required procedures to
schedule inspections,
perform maintenance
and inspections of the
stormwater collection
system. The plan shall
cover inspection
schedules, standard
documentation, and
staff responsibilities.
1. Permit Year 1

1. Was the MS4 O&M
Plan developed: Yes
or No, Status.

DRAFT NCS000431 SWMP
City of Conover
January 27, 2021
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Table 21: Pollution Prevention and Good Housekeeping BMPs
Plan must also be submitted to
DEQ for approval.

City of Conover Public Works
already has maintenance
procedures in place, these will be
used when developing the MS4
O&M plan to ensure consistent
and adequate maintenance is
being done.

2. Submit the
developed O&M Plan
to DEQ for approval.
2. Permit Year 1

2. Was the O & M
Plan approved by
DEQ: Yes or No,
Status;

Date of submittal to
DEQ.

3. Implement the
written and approved
O&M Plan.
3. Permit Years 2-5

3. Was the O&M Plan
implemented, Yes,
No; Status.
4. Administer the
O&M Plan (See BMP
50 & 51).
4. Continuously,

Permit Year 2-5

4. Number of MS4
inspections completed.

49. MS4 Training

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Table 21: Pollution Prevention and Good Housekeeping BMPs
Provide MS4 training to
municipal and contracted staff to
minimize pollutants in the
stormwater collection system,
prevent unnecessary damage and
wear on the system, increase
awareness of stormwater issues,
and show the procedures on how
to deal with stormwater related
issues.

These trainings will cover: illicit
discharges, pollution prevention,
outreach, how to respond to IDDE
or post construction issues, spill
prevention and response
procedures, municipal facility
requirements, construction runoff,
Post construction ordinance and
procedures, pesticide and fertilizer
management, IDDE Plan
procedures and requirements,
IDDE ordinance, and good
housekeeping procedures.
1. Hold MS4 training
events to educate staff
on MS4 topics listed in
the referencing BMPs.

The topics covered and
number of participants
will be recorded at
each training.
1. Annually

Permit Years 1-5

1. Number of trainings
held;
Number of personnel
trained.

50. MS4 Inspection
Proactively perform MS4
inspections to ensure clogged
lines, non-functioning SCMs, and
drainage inadequacies are
identified.
1. Inspect the MS4
infrastructure (pipes,
major outfalls,
stormwater
conveyances, and
basins) to ensure
functionality.

1. Continuously

Permit Years 1-5

1. Number of catch
basins and
conveyances
inspected; Number of
conveyance issues
found/reported.
51. MS4 Maintenance
MS4 inspections to ensure
clogged lines, non-functioning
basins, and drainage inadequacies
are repaired. If the municipality
cannot reasonably maintain issues
with MS4 infrastructure found in
a permit year, it can be contracted
out to a qualified licensed
professional if the City so chooses
1. Inspect all
municipal catch basins
and conveyances on an
annual basis and/or
upon report of
maintenance being
required.
1. See BMP 50

1. See BMP 50

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Table 21: Pollution Prevention and Good Housekeeping BMPs
to do so. The City will utilize
public works resources to
maintain the MS4 infrastructure;
or the issue will be included in the
City’s capital improvement
project list, and appropriately
prioritized depending on the
nature of the repair.

2. Maintenance will be
completed upon
finding through
inspection or receiving
reports of MS4
infrastructure in poor
condition.
2. Continuously,

Permit Years 1-5

2. Number of MS4
cleanings/maintenance
actions performed.

Permit
Ref.
3.7.4: Municipal SCM Operation and Maintenance Program
Measures to manage municipally-owned, operated, and/or maintained structural SCMs that are installed for
compliance with the permittee’s post-construction program. The permittee shall maintain a current inventory
of SCMs, perform SCM inspections and maintenance, and shall establish specific frequencies, schedules, and
documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
52. Municipal SCMs Operation & Maintenance (O & M) Plan
The maintenance procedures and
inventory of the municipal SCMs
will be kept up to date.

However, at the time of
developing this SWMP the City
of Conover does not currently
have a municipally owned SCM.
Should the City need to install one
following expansion, these
procedures will be followed.
1. Maintain an
inventory of
existing municipally-
owned
SCMs with
information
including type, year
built, date of last
inspection, and
maintenance actions.
1. See BMP 35

1. See BMP 35
2. Develop and
maintain SCM
Operation and
Maintenance Plans for
each municipally-
owned SCM.
2. Continuously

2. Were any
municipal SCM
O&M’s developed?
Yes, No; Status.

Number of municipal
SCM’s

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Table 21: Pollution Prevention and Good Housekeeping BMPs
3. Review/Update
SCM inventory as
necessitated
by new municipal
development.
3. See BMP 53

3. See BMP 53
53. Municipal SCMs
The municipal SCM/s operation
and maintenance program will
ensure the stormwater structures
are being managed/maintained in
a way that does not negatively
impact water quality. The SCMs
will be maintained in a scheduled
and well-defined manner written
in its O&M plan. Municipal
SCMs will be included in the
SCM inventory sheet but
differentiated by owner
(municipally owned and privately
owned).

However, at the time of
developing this SWMP the City
of Conover does not currently
have a municipally owned SCM.
Should the City need to install one
following expansion, these
procedures will be followed.
1. Verify the existing
list of municipal SCMs
is correct by visiting
the sites to determine
type and condition.
Done once per permit
cycle.
1. Permit Year 1

1. Is the SCM list
complete: Yes or No,
Status
(Location and type to
be documented).
2. Maintain Inventory
of municipally owned
SCMs. Add all new
SCMs as they are
constructed.
2. Continuously

Permit Years 1-5

2. Did the inventory
require any municipal
SCMs to be added
Yes, No; Status.
3. Perform annual
inspection and
maintenance of
municipally owned
SCMs to ensure the
operation and
maintenance plan is
being followed.
3. Annually

Permit Years 1-5

3. Number of
municipal SCMs
inspections done.
4. Document and
correct issues found
during inspections.
4. Annually

Permit Years 1-5

4. Number of issues
identified/recorded;

Number of corrective
actions/repairs taken.

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Table 21: Pollution Prevention and Good Housekeeping BMPs
5. Should a municipal
SCM be installed,
Training on the
maintenance of the
SCM and its function
shall be held.

5. See BMP 49 5. See BMP 49

Permit
Ref.
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide
routine pollution prevention and chemical use, storage and handling training, and shall ensure compliance with
permits and applicator certifications.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
54.

Pesticide, Herbicide and Fertilizer Training to Staff
Measures to minimize water
quality impacts from the use of
landscaping chemicals. The only
staff who will be allowed to apply
pesticides, herbicides, or
fertilizers will be certified
individuals who use methods that
minimize the amounts used.
1. Provide training to
staff on the use,
storage, and handling
to get officially
certified. The training
will include methods
of using minimal
chemicals to reduce
harmful effects,
especially around
SCM maintenance.

1. See BMP 49

1. See BMP 49
55. Pesticide, Herbicide and Fertilizer Compliance
Ensure compliance with permits
and certifications for the
administering of pesticides,
herbicides and fertilizer to ensure
application of product is less
impactful to stormwater runoff.
Only certified landscapers/
sprayers are the ones applying
pesticides, herbicides, and
fertilizers.
1. Maintaining copies
of
licenses/certifications
of all staff and
contractors who use
landscaping chemicals.
1. Annually

Permit Years 1-5

1. Number of certified
municipal personnel.

Permit
Ref.
3.7.6: Vehicle and Equipment Cleaning Program
Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle
and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities
subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution
prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and
documentation.

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Table 21: Pollution Prevention and Good Housekeeping BMPs
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
56. Vehicle and Equipment Cleaning
Prevent or Minimize
Contamination of Stormwater
Runoff from all areas used for
Vehicle and Equipment Cleaning.

The City of Conover utilizes their
municipal wash bay and most
municipal facilities that hold
vehicles have a wash bay of their
own (police department and fire
station). These wash basins drain
into the sanitary sewer and are
used to minimize runoff pollution
from maintaining municipal
vehicles. These specific
procedures will be included in
each facilities O&M plan.
1. Provide routine
pollution prevention
training to staff.
2. See BMP 49

2. See BMP 49
2. Wash all municipal
light vehicles, City
emergency vehicles,
and equipment using
the method written in
their facilities O&M
plan.
2. Continuous

Permit Years 1-5

2. Were municipal
vehicles washed using
the wash bay?
Yes/No/Status
57. Vehicle and Equipment Maintenance
Measures to ensure that the waste
generated by vehicle maintained
at municipal facilities (included,
but not limited to, oils, any
running fluids, batteries, belts and
other non-fluid vehicle waste) is
being disposed of properly.
1. Ensure the City has
obtained a NPDES
industrial permit for all
subject municipal
facilities/operations.
1. Permit Years 1

1. Have all municipal
NPDES permits been
obtained?
Yes/No/Status

Number of permitted
municipal industrial
facilities
2. Perform waste
inspections during
facility inspections
(See BMP 46).
2. See BMP 46

2. See BMP 46.

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Table 21: Pollution Prevention and Good Housekeeping BMPs
3. Provide routine
pollution prevention
and waste management
training to staff.
3. See BMP 49

3. See BMP 49
Permit
Ref.
3.7.7: Pavement Management Program
Measures to reduce pollutants in stormwater runoff from municipally-owned streets, roads, and parking lots
within the permittee’s corporate limits. The permittee shall implement measures to control litter, leaves, debris,
particulate and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and
documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
58. Street and Parking Lot Sweeping
Measures to reduce pollutants in
stormwater runoff from
municipally owned streets, roads,
and parking lots within the
permittee’s corporate limits.

The City of Conover owns a street
cleaning vehicle which is ran on a
weekly basis.

1. Street/curb and
gutter sweeping will
be done weekly to
reduce road pollutants
in runoff.
1. Weekly

Permit Years 1-5

1. Total number of
lane miles swept.
59. Litter Management
Collect litter in public areas and
parking lots to reduce negative
impacts on water quality.
1. City owned trash
receptacles are
emptied twice a week,
or on an as needed
basis.
1. Continuous

Permit Years 1-5

1. Number of full time
employees
responsible;

2. The City will host
its annual “litter sweep
day” to both collect
litter and encourage
public participation.
2. Annually

Permit Years 1-5

2. Number of staff
and/or volunteers at
the litter sweep.
60. Leaf Collection and Yard Waste

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Table 21: Pollution Prevention and Good Housekeeping BMPs
Implement measures to control
leaves and debris within the
municipal City limits (to include
all properties).
1. Collect leaves with
vacuum-style
equipment from
October 15 through
January 15, with each
street collected twice
during this period.
1. Annually

Permit Years 1-5
1. Volume of leaves
collected
61. Vehicle Pollutant Management
Measures to prevent and minimize
contamination of stormwater
runoff from vehicle pollutants
following an accident.
1. Train first
responders for
minimizing, collecting
and disposing of fluids
and other vehicular
pollutants following an
accident.
1. Annually

Permit Years 1-5

1. Number of first
responders (staff)
trained and date of
training.
2. Continue equipping
the first responder
vehicles with spill kits
and material
containment tools.
2. Annually

Permit Years 1-5

2. Amount of materials
used/replaced in kits.
3. Public Education to
include information
about vehicle leaks in
distributed materials
and other educational
resources.
3. Annually

Permit Years 1-5

3. Number of vehicle
pollution educational
materials handed out.
4. Illicit Discharge
enforcement for
significant vehicle
leaks from parked cars.
4. Annually

Permit Years 1-5

4. Number of vehicle
IDDE issues
documented; number
of vehicle IDDE issues
enforced/corrected.