HomeMy WebLinkAboutNCS000488_Valdese Draft SWMP v3_20201207
Draft Stormwater Management Plan
Town of Valdese
NCS000488
December 7, 2020
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 ................................................................................................................. 14
4.4 Co-Permittees .............................................................................................................................. 15
4.5 Measurable Goals for Program Administration .......................................................................... 15
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 17
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 25
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 29
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................... 38
PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 41
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
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 1
PART 1: INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the Town of
Valdese will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm
Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of
reducing pollutants in stormwater runoff to the maximum extent practicable.
This SWMP identifies the specific elements and minimum measures that the Town of Valdese 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 Town of Valdese and located within the corporate limits of the Town of Valdese.
In preparing this SWMP, the Town of Valdese 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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Town of Valdese
December 7, 2020
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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: Seth Eckard
Title: Town Manager
Signed this ____ day of 20____ .
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 3
PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This Stormwater Management Plan (SWMP) applies throughout the corporate limits of the Town of Valdese, including all
regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits
of Town of Valdese as of the date of this document.
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Town of Valdese
December 7, 2020
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3.2 Existing MS4 Mapping
The current MS4 mapping includes outfalls located within the Town of Valdese. In the future, the Town 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 Town of Valdese 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 Town 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.
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Town of Valdese
December 7, 2020
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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.
3.3 Receiving Waters
The Town of Valdese 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
Catawba River 11-(37) WS-
IV, B; CA
C N/A
Hoyle Creek 11-45-(2)
WS-IV; CA
C N/A
MCGalliard Creek 11-44-(3)
WS-IV; CA
C Fish Community (NAR, AL, FW)
Dye Branch 11-44- (2)
WS-IV; PA
C N/A
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Town of Valdese
December 7, 2020
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3.4 MS4 Interconnection
The Town of Valdese MS4 is interconnected with another regulated MS4 and directly discharges stormwater into the
Town of Rutherford College via the hospital property.
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)
N/A N/A N N
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Town of Valdese
December 7, 2020
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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
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
Corynorhinus
townsendii
virginianus
Virginia big-eared bat Vertebrate Endangered
Alasmidonta varicosa Brook floater Invertebrate At risk species
Ophiogomphus
edmundo
Edmons’s Snaketail Invertebrate At risk species
Macromia margarita Margarita River
skimmer
Invertebrate At risk species
Microhexura
montivaga
Spruce-fir moss
spider
Invertebrate Endangered
Hexastylis naniflora Dwarf-flowered
heartleaf
Vascular Plant Threatened
Liatris helleri Heller's blazing star Vascular Plant Threatened
Hedyotis purpurea
var. montana
Roan Mountain Bluet Vascular Plant Endangered
3.7 Industrial Facility Discharges
The Town of Valdese 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.
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Town of Valdese
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Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number Facility Name
NCGNE0787 Bimbo Bakeries USA Inc.-Valdese
NCG170364 Valdese Weavers Inc. (Crescent Street Plant)
NCG080707 Town of Valdese Public Works Facility
NCG030235 Saft America, Inc.
NCG170073 Valdese Weavers Inc. (Perkins Road)
NCG170126 Valdese Weavers Inc. (Lovelady Road)
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the Town of Valdese as summarized in
Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. The
Town of Valdese has evaluated residential and charity car washing and street washing for possible significant water
quality impacts.
Street washing discharges are addressed under the Pavement Management Program in Part 10 of this SWMP. The
Division has not required that other non-stormwater flows be specifically controlled by the Town of Valdese.
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 Town of Valdese to determine whether they may significantly impact water quality. The Town
of Valdese will address the possibility of the below mentioned water quality impacts through public education and good
housekeeping, as outlined in Part 5 BMP 3-7 and Part 10 BMP 45-47, 49, 53, 54, 56, 57 and 61 with a focus on the
training of good housekeeping practices.
Table 6: Non-Stormwater Discharges
Non-Stormwater Discharge Water Quality Impacts
Water line and fire hydrant flushing Incidental
Landscape irrigation Incidental
Diverted stream flows Incidental
Rising groundwater Incidental
Uncontaminated groundwater infiltration Incidental
Uncontaminated pumped groundwater Incidental
Uncontaminated potable water sources Incidental
Foundation drains Incidental
Air conditioning condensate Incidental
Irrigation waters Incidental
Springs Incidental
Water from crawl space pumps Incidental
Footing drains Incidental
Lawn watering Incidental
Residential and charity car washing Possible
Flows from riparian habitats and wetlands Incidental
De-chlorinated swimming pool discharges Incidental
Street wash water Possible
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Town of Valdese
December 7, 2020
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Flows from firefighting activities Incidental
3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the Town of Valdese is aware of other significant water quality
issues within the permitted MS4 area. Target pollutants as listed below are major contributors of the stream impairment.
Measures to improve water quality are in place and being improved upon.
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. In addition, the Town of Valdese has evaluated schools, homeowners and businesses as target audiences that are
likely to have significant stormwater impacts.
Within the table below the following target pollutants have been commonly found to be concerns within the community.
Litter: A Proliferation of Roadside Litter has been noted by citizens and public officials within the Town.
Roadside litter is an ongoing issue for the Town. This litter poses a threat to both our water bodies and the MS4
infrastructure, as the litter can create clogs and backups that damage the pipelines leading back to the stream. Some litter
even poses a threat to groundwater if chemical leaching or breakdown of components into heavy metals occurs due to
weathering of the litter. Most litter is found on the side of major roads and in select residential areas.
Sediment: Previously installed erosion control measures have been removed or fallen
Sediment buildup is largely attributed to mismanaged construction sites with fallen or incorrectly installed sediment
fences. Citizens and code enforcement officers have noted several cases of 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 code enforcement has responded and had the issue solved, but even being down for a short time can prove to
have significant effects. Erosion control fences are required for sediment control permits during construction by the DEQ
throughout the entire construction process.
Gray Water: Straight piping washing machines out of the house
Residents have noted a few homes have had their washing machines straight-piped out of their homes by creating
makeshift piping using water hoses exit at windows. Homes are to be connected to the appropriate sewer system. This
proves to be a source of detergents/soaps entering our storm drains in residential neighborhoods. In addition: residential,
charity, and municipal car washes allow for soaps or waxes to enter the storm drain when vehicles are not being cleaned
in the correct areas (such as vegetated patches or in areas that do not have storm drains). This allows for toxic
contaminants to enter our waterways via the storm drain system.
Fats Oils and Grease: Health Department and Valdese Utilities staff has noted several cases where restaurants do
not appropriately maintain grease traps.
The Health Department have reported several restaurants in Valdese for not maintaining or properly using grease traps.
This has led to cases of the restaurants allowing the grease to drip onto nearby impermeable surface – which would
eventually lead to water quality issues. Overflow from a lack of maintenance or throwing out the grease with general
waste contributes to this problem. This is a health violation since the grease poses a physical risk, but it also can impair
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December 7, 2020
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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, but some restaurants have been noted as repeat violators.
Chemicals: Totes have been noted in industrial areas not properly labeled or stored
Town staff, along with some citizens have reported containers of unknown/unmarked chemicals in select industrial sites,
leading to potential soil and water contamination, and/or incorrect spill cleanup procedure. In addition to not labeling the
containers correctly, the Town has noted that the containers are not being correctly stored in a way to minimize risk to the
water bodies from seepage, damage to the containers, or spills. Code enforcement has responded to these reports.
Animal Operations: A challenge to ensuring water quality for several factors.
Animal operations are agriculture operations that raise cows, pigs, chickens, or other livestock as a product, be it from
meat or byproducts of the animal, the latter being more problematic as the excess nutrients will lead to eutrophication
which can eventually causing hypoxia in the water body. In a similar vein, agricultural runoff often caries excess fertilizer
which also will cause eutrophication in streams with its cascading effects. The Town of Valdese does not permit
commercial animal agriculture within the Town limits, but does allow for urban chickens and limited livestock for
personal use. Urban farming is a common theme within the Town. Upon meeting appropriate requirements one can
obtain a zoning permit to allow farm-like animals
Underground storage tanks: Storage devices installed below ground that contain hazardous materials/waste.
These tanks can contain gasoline, fuels such as propane, industrial chemicals/oils, and most often human waste in areas
not directly connected to the sanitary sewer. Any underground storage tank must be well maintained/monitored, and
correctly installed due to the risk of them leaking. The leaks can cause whatever chemical the tank is storing to leak into
the ground, harming the soil, groundwater/water table, and even surface waters as they are being fed from groundwater. If
a fuel or industrial chemical tank is leaking, the chemical will leach into the soil – leading to toxic soil, contaminated
groundwater, and possibly impairing a stream/water body.
Some areas of the Town that were more recently annexed still have homes that utilize septic tanks. If a septic tank is
leaking, it can 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 Town.
Illicit discharges: Originate from a variety of sources, with an equally varied number of effects dependent on the
chemical that is released.
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: When residents, businesses, or municipal employees dump waste randomly in non-permitted
dumping areas.
This waste can widely vary, causing a variety of problems. For example, citizens dumping televisions on the side of the
road to avoid dumping fees, which allows for the metals or chemicals inside the tv to leach out as stormwater passes it
(mercury, lead, and other metals). It can be a case of businesses dumping waste in watershed areas where runoff passes
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Town of Valdese
December 7, 2020
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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 Town provides
municipal residential solid waste pick-up weekly to all Town residents.
Improper disposal of waste:
Improper disposal of waste is problematic because it allows chemicals, or difficult to manage waste, to enter the
environment in ways that may be hard to track. For example; not giving a car battery to the correct waste management
facility can allow for battery acid and lead to enter the soil which drains/collects in the groundwater. 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.
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
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/Bona fide Farms 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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Town of Valdese
December 7, 2020
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PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure
The Town of Valdese has contracted Western Piedmont Council of Governments (WPCOG) to coordinate Stormwater
Management Plan efforts, to ensure the Town is facilitating Best Management Practices (BMPs) to protect water quality.
While WPCOG will be the primary operator of the program the Town of Valdese 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
Town Manager Seth Eckard Administration, Town
of Valdese
SWMP Management Senior Planner/Natural
Resources
Administrator
Johnny Wear WPCOG
Public Education &
Outreach
Senior Planner/Natural
Resources
Administrator
Johnny Wear WPCOG
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Town of Valdese
December 7, 2020
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Public Involvement &
Participation
Senior Planner/Natural
Resources
Administrator
Johnny Wear WPCOG
Illicit Discharge
Detection &
Elimination
Compliance Manager Todd Justice WPCOG
Construction Site
Runoff Control
N/A N/A NCDEQ – Asheville
Regional Office
Post-Construction
Stormwater
Management
Stormwater
Administrator
Jack Cline WPCOG
Pollution
Prevention/Good
Housekeeping for
Municipal Operations
Senior Planner/Natural
Resources
Administrator
Johnny Wear WPCOG
Municipal Facilities
Operation &
Maintenance Program
Stormwater
Administrator
Jack Cline WPCOG
Spill Response Program Stormwater
Administrator
Jack Cline WPCOG, Fire
Department
MS4 Operation &
Maintenance Program
Public Works
Departments
Greg Padgett Town of Valdese
Municipal SCM
Operation &
Maintenance Program
Public Works
Departments and
Stormwater
Administrator
Greg Padgett
Jack Cline
Town of Valdese
WPCOG
Pesticide, Herbicide &
Fertilizer Management
Program
Public Works
Departments and
Stormwater
Administrator
Greg Padgett
Jack Cline
Town of Valdese
WPCOG
Vehicle & Equipment
Cleaning Program
Public Works
Departments
Greg Padgett
Town of Valdese
Pavement Management
Program
Public Works
Departments
Greg Padgett
Town of Valdese
4.2 Program Funding and Budget
In accordance with the issued permit, the Town of Valdese 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.
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The Town of Valdese 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 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 $23,342.00. The Town will be responsible for the cost of
the annual NPDES permit renewal, which is to be paid to the state. Any fees charged to the development community for
BMP Inspections, Plan Review, and other associated fees will be used to help offset cost. The Town may determine that
stormwater utility fees should be implemented; these fees would be collected by the Town through tax or utility bills.
Should the Town of Valdese 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 Town of Valdese would be required
to renew the two-year contract, in years 2021 and 2023, to fully carry out the 5 year NPDES permit cycle.
4.3 Shared Responsibility
The Town of Valdese will share the responsibility, with WPCOG (referred to as entity), to implement the following
minimum control measures, which are as stringent as the corresponding NPDES MS4 Permit requirement. The Town of
Valdese remains responsible for compliance if the other entity fails to perform the permit obligation and may be subject to
enforcement action, if neither the Town of Valdese, nor the other entity fully performs 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 Partnership Y
Public Education and
Outreach Program
WPCOG Stormwater Partnership Y
Public Involvement and
Participation Program
WPCOG Stormwater Partnership Y
Illicit Discharge Detection
and Elimination Program
WPCOG Stormwater Partnership Y
Construction Site Runoff
Control Program
NCDEQ N/A
Post-Construction Site
Runoff Control Program
WPCOG Stormwater Partnership Y
Pollution Prevention and
Good Housekeeping
Programs
WPCOG Stormwater Partnership Y
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4.4 Co-Permittees
There are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000488 for the
Town of Valdese.
4.5 Measurable Goals for Program Administration
In response to the MS4 Inspection Report for the Town of Valdese - Program Implementation, Documentation &
Assessment (II.A2, II.A.3, II.A.4, II.A.6, III.A. and III.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 Town of Valdese 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 Town of Valdese 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 NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 16
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 NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 17
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The Town of Valdese 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.
In reference to MS4 Permit Self Audit Report - Public Education and Outreach, Permit Citation II.B.2.b., II.B.2.c, and
II.B.2.h: Stormwater impact target audiences and sources will be identified. The Town of Valdese will administer public
outreach to educate residence, businesses, schools, industry, employees and the development community. The extent of
exposure will be recorded and evaluated (Reference BMP 3-9).
The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by the Public
Education and Outreach Program, are summarized in Table 12 below. In addition, the Town of Valdese is required to
inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping and improper
disposal of waste.
Table 12: Summary of Target Pollutants & Audiences
Target Pollutants/Sources Target Audience(s)
Litter Residents, Businesses, Schools
Sediment Construction Activity
Gray Water Residential
Fats, Oils and Grease Businesses (Restaurants)
Animal Operations Bona fide farms/Urban Farming
Underground Storage Tanks Businesses and Residents
Chemicals Industrial, Business and Residential
Illicit Discharges General Public, Businesses, Municipal Employees
Illegal Dumping General Public, Businesses, Municipal Employees
Improper Disposal of Waste General Public, Businesses, Municipal Employees
The Town of Valdese 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
Continue to utilize the WPCOG
stormwater outreach program to
develop new educational
materials to be distributed at
1. Develop and
distribute new fliers to
raise general
stormwater awareness.
1. Permit Year 1
1.-5. Number of flyers
distributed at each
event
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 18
Table 13: Public Education and Outreach BMPs
events, at Town Hall, and/or
through mailers to ‘water bill’
addresses.
2. Develop and
distribute new fliers
educating about illicit
discharges.
2. Permit Year 2
Number of flyers left
for distribution at
Town Hall;
Number of fliers sent
through the mail.
3. Develop and
distribute new fliers
for illegal dumping’s
impacts on stormwater
quality.
3. Permit Year 3
4. Develop and
distribute new fliers to
raise awareness on
how chemicals impact
stormwater.
4. Permit Year 4
5. Develop and
distribute new fliers to
educate on the
importance of proper
waste disposal.
5. Permit Year 5
4. Public Event Outreach
Provide stormwater educational
information to the citizens
through outreach activities at
community events. The Town will
maintain its outreach booth at the
annual Waldensian Festival to
provide educational materials and
to raise awareness of stormwater
issues.
1. Staff will have
continue to have a
booth at the annual
Waldensian Festival to
disperse stormwater
outreach
materials/awareness
through the use of
interactive educational
games and activities.
1. Annually
Permit Years 1-5
1. Number of attendees
at outreach booth
during the Waldensian
Festival.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 19
Table 13: Public Education and Outreach BMPs
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.
2. Staff will provide
alternative outreach
opportunities if the
Waldensian Festival is
canceled, or as an
additional outreach
supplement. Such
opportunities include
but are not limited to:
an outreach booth at
the Valdese Library,
and/or an outreach
booth at farmers
markets, or other
events if they are still
available.
2. Annually
Permit Years 1-5
2. Number of attendees
at alternative outreach
booth
Event/location of
alternative outreach
booth
5. Student/teacher outreach
Provide educational information
to students and teachers through
classroom, workshop, and hands-
on activities related to stormwater
BMPs. The Town of Valdese will
continue to utilize the WPCOG
stormwater outreach program to
educate these target audiences to
raise stormwater awareness.
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
Heritage 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 that include
teachers who work
with Valdese students..
2. Annually
Permit Years 1-5
2. Number of
workshops provided;
Number of teachers
who attended each
teacher outreach event.
3. Staff will create a
presentation covering
stormwater topics to
be presented in digital
classrooms and/or
provided to teachers.
The PowerPoint will
be presented by
teachers and/or staff
to students in a safe
method such as an
online classroom.
3. Annually
Permit Years 1-5
3. Number of
presentations provided
by teachers or staff
Number of students
present during the
presentation
6. Printed Materials
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 20
Table 13: Public Education and Outreach BMPs
Staff will design new printed
materials for target audiences to
aid stormwater education and will
distribute said materials once they
are designed/developed. The
Town will continue to distribute
these materials at outreach events,
available at Town hall, and
through water bill mailers.
1. Staff will create new
printed materials for
distribution that
addresses stormwater
best management
practices.
1. Permit Year 1 1. Were new outreach
materials created? Yes,
No; Status.
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 to local
government officials, municipal
staff, educators, local businesses,
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
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 21
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)
that are 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
Town to correctly focus education
efforts in those areas.
Each target pollution violation
will be recorded with the type of
pollution violation, source of the
pollution, and the pollutant itself.
This will be used to determine
what audiences were responsible
for the violation and what can be
done to prevent these issues in the
future through outreach efforts.
1. Evaluate the
presence of the
following target
pollutants within the
Town: litter,
sediment, gray water,
fats, oils, grease, urban
farming, underground
storage tanks, super
fund sites, chemicals,
illicit discharges,
illegal dumping and
improper disposal of
waste to identify
where outreach can be
improved to address
these pollutants.
1. Annually
Permit Years 1-5
1- 2. Number and
types of target
pollutant violations
Were SWMP revisions
needed to address
target pollutants or
audiences.
2. Evaluate the
following target
audiences to determine
where outreach efforts
should be focused to
minimize stormwater
pollutants: residents,
businesses, schools,
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
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 22
Table 13: Public Education and Outreach BMPs
Maintain the already established
webpage designed to convey
information about the stormwater
program. The Town webpage
will: convey the importance of
stormwater quality, include a link
to the WPCOG Stormwater
Partnership web page, and host
the current SWMP, stormwater
ordinance, and annual report. The
WPCOG Stormwater Partnership
webpage will provide educational
resource links, compliant
procedures, stormwater
regulations, stormwater permit
information, and good
housekeeping information.
1. Maintain and update
stormwater program
information on the
existing Town of
Valdese website.
1. Annually
Permit Years 1-5
1. Did the web page
need revisions? Yes,
No; Status;
Date updated SWMP
was added to
municipal website.
2. WPCOG staff will
maintain and update
the WPCOG
stormwater web page
by: verifying all links
and contact
information is
current/active, and
posting the current
year educational
materials.
The municipal
stormwater webpage
will post the current
SWMP, stormwater
ordinance, and annual
assessment..
2. Annually,
Permit Years 1-5
2. Was annual self-
assessment uploaded
to the Town of
Valdese’s website?
Yes, No; Status;
Did links, contact
information, or
documents need to be
updated? Yes, No;
Status;
Were new/current
educational materials
added to site? Yes, No;
Status.
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
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 23
Table 13: Public Education and Outreach BMPs
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
The Town of Valdese will
continue to provide a hotline that
functions as a way for citizens to
contact the Town to report illicit
discharges, stormwater/post
construction issues, outreach
questions and concerns, and MS4
related concerns.
1. Identify 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.
3. Continuously.
Permit Years 1-5
3. Number of hotline
phone calls received
by type/purpose of
call.
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.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 24
Table 13: Public Education and Outreach BMPs
5. Publicize contact
information on the
Town and WPCOG
Stormwater webpages
as well as the Town of
Valdese Facebook
page.
5. Continuously,
Permit Years 1-5
5. Number of hotline
calls received overall.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 25
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
In reference to MS4 Permit Self Audit Report – Public Involvement and Participation, Permit Citation II.C.2.a. Volunteer
Community Involvement Program: The Town will begin implementing a community volunteer program to gain citizen
participation to complete Stream/lake front clean-ups (BMP 18). The Town of Valdese has an established hotline (main
number for the Town 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.
This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that
complies with applicable State, Tribal, and local public notice requirements. The Town of Valdese 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).
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
concerns, as well as have input on
the stormwater program.
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.
2. Use the form to
record and track
responses, inputs,
issues, and concerns
for metric reporting.
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;
Purpose of each
question, report, or
comment.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 26
Table 14: Public Involvement and Participation BMPs
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 Town of
Valdese Facebook page 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
Town of Valdese
Facebook page to
promote public
involvement and
participation related to
stormwater programs,
events, and projects.
The Facebook page
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 Town of
Valdese Facebook
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.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 27
Table 14: Public Involvement and Participation BMPs
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 Town of Valdese’s
website.
Responses/results of
the survey will be
analyzed for reporting
and evaluation.
1. Annually
Permit Years 1-5
1. Number of surveys
completed.
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
Provide volunteer opportunities
for ongoing citizen participation
through stream cleanup activities.
Due to the COVID-19 pandemic,
additional safety precautions will
need to be followed. Participants
will need to be spaced out in at
least 6ft intervals along the
stream, and materials (trash bags,
gloves, ‘litter grabbers’, printed
materials) will not be shared. Any
reused material, such as the
grabbers, will need to be sanitized
before and after the cleanup event.
Masks will be required to
participate in the event.
1. Hold stream cleanup
efforts by engaging
groups to conduct
stream cleanup
activities in
appropriate areas. The
events will be
promoted by the Town
and WPCOG, with a
focus on civic groups.
For the Town of
Valdese the stream
cleanups will focus on
McGalliard Creek,
Lake Rhodhiss, 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.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 28
Table 14: Public Involvement and Participation BMPs
2. Provide all materials
for stream cleanup
activities (i.e. gloves,
trash bags, and trash
pickers) hosted by
Town and WPCOG.
2. Annually
Permit Years 1-5
2. Number of stream
clean up materials
distributed.
3. The Town 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 Town website,
and flyers will be
distributed at Town
Hall.
3. Annually
Permit Years 1-5
3. Was the event
publicized? Yes, No;
Status;
Number of participants
per event.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 29
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
Per the MS4 Inspection Report the Town has written procedures for implementing an IDDE Program. To increase efforts
the Town will locate priority areas likely to have illicit discharges, conduct routine dry weather outfall inspections,
identify illicit discharges and trace sources, eliminate the source(s) of an illicit discharge, and evaluate and assess the
IDDE Program.
The Town has a stormwater ordinance and other regulatory mechanisms that provide the legal authority to prohibit illicit
connections and discharges to the MS4. The documents will be reviewed, and if necessary, updated to maintain the
program and enforce IDDE issues effectively.
The Town of Valdese has all of the MS4 mapping completed; however as development occurs the map and associated
components will be updated accordingly.
In the last permit cycle the Town did not conduct dry weather screening or maintain written procedures for dry weather
field activity (II.D.2.d. Dry Weather Flow Program). Within the Stormwater Management Plan a schedule is to be created
to conduct dry weather screening quarterly. Data such as date screening occurred, location of inspected outfall, and
photos of outfall will be recorded in GIS.
The Town of Valdese 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 Town to identify priority areas based on historical data.
Further, the Town will train municipal staff and the general public to identify illicit discharges and illegal dumping
through the use of educational outreach materials and training opportunities. Previously, no training had been
administered (II.D.2.g. & h.). 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 Town through point contact on the webpage. A webpage portal
will be established on the WPCOG website, as well as, linked to on the Town 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 Town of Valdese will develop, manage, implement, document, report, and enforce an Illicit Discharge Detection and
Elimination Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs.
Table 15: Illicit Discharge Detection and Elimination 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
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 30
Table 15: Illicit Discharge Detection and Elimination BMPs
Maintain the existing municipal
storm sewer system map that
shows stormwater
conveyances/infrastructure. and
waters of the United States that
are receiving stormwater
discharges. The MS4 map will be
continuously updated for
completeness.
1. When new
conveyances and
outfalls are located or
constructed, add new
infrastructure to the
existing map; to be
updated on an annual
basis.
1. Annually
Permit Years 1-5
1. Report whether or
not new outfalls were
identified and if so,
how many were
identified during the
permit year and how
many have been
identified over the
permit term.
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
Review existing Ordinance 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.
1. Review the
ordinance and update
if revision is required.
Revisions will require
council approval.
1. Annually
Permit Years 1-5
1. Were revisions to
the ordinance needed?
Yes, No; Status.
If revisions were
made; Date of the
revisions to the
Ordinance
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 Establishment and Revisions
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 31
Table 15: Illicit Discharge Detection and Elimination BMPs
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 Town of
Valdese had IDDE standard
operating procedures included in
the 2013 SWMP, this IDDE plan
will build upon those and better
define the IDDE standard
operating procedures.
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
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.
Prior violations will be pulled
from the Division of waste
management site locator tool as
well as prior recorded violations.
1. Use MS4 map to
locate outfalls near
high pollution risk
areas.
1. Permit Year 1
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 to add
additional high priority
areas should they be
found or new ones
develop.
2. Annually,
Permit Years 1-5
2. Were additional
priority areas
determined? Yes, No;
Status;
Number of Priority
areas added upon
revision.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 32
Table 15: Illicit Discharge Detection and Elimination BMPs
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 Town will be
broken into 5 sections, with at
least one section (20%) being
inspected each permit year. If
additional outfalls are located,
they will be included in further
dry weather
inspections/scheduling.
1. Establish a
procedure to divide the
Town and create a
schedule for dry
weather inspections for
known outfalls. The
procedures will be
defined by the Towns
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.
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 Towns
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. IDDE Plan Enforcement and
Documentation
Maintain existing documentation
for recording IDDE violations,
illicit discharges, illegal dumping
and any non-stormwater
discharges identified as
significant contributors of
pollutants to the MS4. The
procedures for enforcement will
1. Monitor priority
areas likely to have
illicit discharges (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.
2. See BMP 26
2. See BMP 26
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 33
Table 15: Illicit Discharge Detection and Elimination BMPs
be defined in the IDDE plan (See
BMP 22).
3. Evaluate and assess
the IDDE
plan/program –
Identify where
improvements can be
made based on data
collected.
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
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.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 34
Table 15: Illicit Discharge Detection and Elimination BMPs
Staff will create a 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.
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.
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.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 35
Table 15: Illicit Discharge Detection and Elimination BMPs
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
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
1. Train hotline staff in
IDDE awareness,
complaint call
protocols, and the
appropriate contacts
for referral.
1. See BMP 12 1. See BMP 12
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 36
Table 15: Illicit Discharge Detection and Elimination BMPs
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.
2. Utilizing social
media and the Town/
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 for
enabling 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
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
Town and WPCOG
websites and shared
via social media
accounts.
3. See BMP 12
3. See BMP 12
30. IDDE Reporting Web-based Reporting Form
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 37
Table 15: Illicit Discharge Detection and Elimination BMPs
Staff will establish and maintain a
web-based form where IDDE
complaints/reports can be entered
and sent to the appropriate
reporting individual. Publicize the
reporting tool in educational
outreach materials as well as on
the Town of Valdese website.
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 the online
Map.
1. Utilize the GIS
online map layer
(BMP 19) to track the
time of complaint, site
visit, type of complaint
and all
enforcement/resolution
measures.
1. See BMP 19
1. See BMP 19
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 NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 38
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the Town of Valdese 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
State Implemented SPCA Program 15A NCAC
Chapter 04
NCDEQ Part
The Town of Valdese 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
Train municipal staff who receive
calls from the public on the
protocols for referral and
documentation of construction
site runoff control complaints.
This shall build upon the concepts
of previous municipal staff have
taken part in by focusing on
reporting, identifying, and
knowing how to handle
construction runoff violations.
1. Train municipal
staff on proper
handling of
construction site runoff
control complaints.
1. See BMP 49 1. See BMP 49
2. Maintain a list of
trained municipal staff
who have reported
construction run-off
issues.
2. Continuously,
Permit Years 1-5
2. Number of
construction run-off
issues reported by
municipal staff;
Date trained staff
reporting list was
established.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 39
Table 17: Construction Site Runoff Control BMPs
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
Town, 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 Town.
1. See BMP 17
1. See BMP 17
2. Administer the
survey. The survey
will be linked to on the
WPCOG stormwater
webpage and the Town
of Valdese website.
2. See BMP 17
2. See BMP 17
3. Utilize reporting
form (BMP 14) that
will allow citizens and
the development
community (separately
distinguished) 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
Town and WPCOG
websites and social
media.
4. See BMP 14
4. See BMP 14
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 40
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. Waste Management
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;
Date ordinance was
adopted.
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.
If revisions were
needed, Date of
revisions
5. Enforce ordinance
by using the online
GIS map layer to
track and document
construction site
waste concerns and
corrective actions.
5. See BMP 19
5. See BMP 19.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 41
PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
The Town of Valdese 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 audit (2018). Along with the inventory list,
proactive inspections will be administered by Staff semi-annually and the SCM owner will be required to have an
inspection done by a certified private engineer annually to ensure SCM functionality (II.F.2.g.). Upon non-compliance,
enforcement action will be taken, not a common practice in years past, but now the Town 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 Town of Valdese
and discharge into the MS4. These elements are designed to minimize water quality impacts utilizing a combination of
structural Stormwater Control Measures (SCMs) and/or non-structural BMPs appropriate for the community, and ensure
adequate long-term operation and maintenance of SCMs.
In accordance with 15A NCAC 02H .0153 and .1017, the Town of Valdese 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 and Critical Areas
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 42
The Town of Valdese is located completely within a water supply watershed and is required to follow those rules to
ensure drinking water quality is being maintained. This is known as a Qualifying Alternative Program (QAP). The Town
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 NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 43
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 Article N Watershed Protection Section 9-
3151
12/6/10
3.6.3(a) & 15A NCAC 02H.0153(c)
Federal, State & Local Projects
Article N Watershed Protection Section 9-
3152
12/6/10
3.6.3(b) Plan Review Article N Watershed Protection Section 9-
3159-3167
12/6/10
3.6.3(c) O&M Agreement Article N Watershed Protection Section 9-
3165
12/6/10
3.6.3(d) O&M Plan Article N Watershed Protection Section 9-
3165
12/6/10
3.6.3(e) Deed
Restrictions/Covenants
Article N Watershed Protection Section 9-
3163
12/6/10
3.6.3(f) Access Easements Article N Watershed Protection Section 9-
3163
12/6/10
Permit Requirements for
Inspections and Enforcement
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(b) Documentation Article N Watershed Protection Section 9-
3167
12/6/10
3.6.2(c) Right of Entry Article N Watershed Protection Section 9-
3156
12/6/10
3.6.4(a) Pre-CO Inspections Article N Watershed Protection Section 9-
3167
12/6/10
3.6.4(b) Compliance with Plans Article N Watershed Protection Section 9-
3167
12/6/10
3.6.4(c) Annual SCM Inspections Article N Watershed Protection Section 9-
3167
12/6/10
3.6.4(d) Low Density Inspections Article N Watershed Protection Section 9-
3167
12/6/10
3.6.4(e) Qualified Professional Article N Watershed Protection Section 9-
3163
12/6/10
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.6(a) Pet Waste Town Code Section 8-2022 6/4/18
3.6.6(b) On-Site Domestic
Wastewater Treatment
Town Code Section 5-2003, 9-3502 06.26.95, 11/4/2019
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.
A B C D
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 44
Table 20: Post Construction Site Runoff Control BMPs
BMP
No. Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
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
The QAP requirements are applicable to the Town of Valdese.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 45
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. Maintain Legal Authority
The Town has adopted and will
maintain in effect the the Water
Supply Watershed Model
Ordinance (referenced in table 19
above), which gives the Town
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 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. Train staff (field
and office) in WSW
Ordinance procedures
and enforcement
actions.
1. See BMP 49
1. See BMP 49
2. Enforcement of the
WSW Ordinance to
ensure compliance of
new structures. Should
the correct processes
and order not be
followed, a notice of
violation will be
issued to address the
violation.
2. Continuously,
Permit Years 1-5
2. Number of notices
of violations issued;
Number of Civil
Citations issued;
Number of still in
progress of abatement
at time of annual
report.
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).
A B C D
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 46
Table 20: Post Construction Site Runoff Control BMPs
BMP
No. 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 Town’s ordinance and
SOP.
The Town of Valdese requires the
County to hold the Certificate of
Occupancy on all developments
that fall under stormwater
regulations within the Town. The
CO is not issued until all
stormwater requirements
(designs, submittals, and
inspections) are satisfied and the
Stormwater Administrator
approves the issuance.
In recent years, the Town of
Valdese has not had any new
construction that would trigger a
stormwater review. In turn, it was
not reviewed by the MS4 Audit to
determine what modifications
should be made. These best
management practices are
included to define the procedures
that shall be followed should a
fitting project be developed.
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.
If revisions were
needed, Date of
revisions were made
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.
2. See BMP 35
2. See BMP 35
3. Develop and
maintain an SCM
Inventory sheet. Said
sheet will track all
required submittals,
relevant information,
and all projects within
the Town that have
gone through (and/or
are going through) the
stormwater review
procedure.
3. See BMP 35
3. See BMP 35
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 47
Table 20: Post Construction Site Runoff Control BMPs
39. Operation and Maintenance Agreement and Plan
The Operation and Maintenance
(O&M) agreement requires
owners of structural SCMs to
perpetually maintain and operate
the SCM according to the O&M
plan submitted during the plan
review process, and shall require
submission of annual inspection
reports written by a qualified
professional.
1. New SCMs built
within the Town shall
submit an approved
O&M Agreement and
O&M Plan prior to CO,
along with other
submittal requirements.
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 on high density
developments.
1. Ensure each project
has recorded deed
restrictions/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 by the Town.
2. See BMP 35
2. See BMP 35
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.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 48
Table 20: Post Construction Site Runoff Control BMPs
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 monitor potential
unpermitted expansion and apply
enforcement if violations are
found.
1. Prior to issuance of a
CO, a qualified Town
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. Qualified municipal
staff will perform
inspections of all SCMs
(both government and
non-government)
within the Town.
2. Annually,
Permit Year 1-5
2. Number of SCM
inspections completed;
Number of failed
SCM inspections.
3. The Owner of the
SCM 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.
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.
A B C D
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 49
Table 20: Post Construction Site Runoff Control BMPs
BMP
No. 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. Maintain low
density project list to
include existing sites.
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
3. Provide educational
materials 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 online to
guarantee accessibility outside of
office hours. Through tracking
and inspections chronic violators
will be identified.
1. Maintain an
inventory of all
developments and
redevelopments
(public and private)
with SCMs. Update
inventory as projects
are reviewed,
approved, and
constructed.
1. See BMP 35
1. See BMP 35
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 50
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 Towns web page
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
Protective measures have been
established through the adoption of
the pet waste component of the
Phase II Stormwater Ordinance.
1. Maintain Pet
Waste Ordinance to
reduce the amount of
pet waste.
1. Annually
Permit Years 1-5
1. Did Pet Waste
Ordinance require
revisions? Yes, No;
Status.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 51
Table 20: Post Construction Site Runoff Control BMPs
Almost all of the Town of
Valdese’s wastewater is managed
via a sewer system – however
there are still some septic tanks
outside of the town that could
potentially become a source of
fecal coliform pollution. 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.
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 NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 52
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the Town of Valdese
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 Town of Valdese will manage, implement and report the pollution prevention and good housekeeping BMPs as
specified in Table 21 below for each required program. In response to the inefficiencies identified in the MS4 Inspection
Report, municipal facilities were not being inspected, as required per DEQ (II.G.2.b. and g.). Per BMPs 45-61, municipal
facilities and the practices at those facilities will be inspected on an annual basis.
Upon the latest audit (II.G.2.d.) in reference to streets, roads, and public parking lot maintenance, the Town provided a
verbal estimate of the quantity of material removed; however no documentation was available at the time of the
inspection. Several of the BMPs below address this issue by developing, adopting, and maintaining procedures that focus
on pollutant removal in these impervious areas. Permit ref: 3.7.7 BMP’s 58-61 address this prior lack of evaluation and
program implementation. BMP 58 focuses on setting schedules and requirements for street/parking lot sweeping. BMPs
59 and BMP 60 focuses on minimizing and collecting litter/debris, with BMP 59.B.2 working in part as a community
outreach program. BMP 61 addresses procedures for cleaning the oils, fluids, and debris that can come from car accidents
by utilizing the developed standard spill procedures as necessary according to II.G.2.c.
The Town of Valdese uses a vac-truck to clean the storm sewer conveyance system. There was a lack of documentation
addressing when the cleanings occurred; therefore a more abundant effort will be made documenting activities associated
with maintenance of the MS4. Permit Ref: 3.7.3 BMP’s 48-51 focus on the training, inspection, and maintenance of said
system. BMP 48 develops the required O&M plan which defines procedures/schedules for each facility, BMP 49 trains
staff to perform maintenance using correct procedures, and BMP 50 focuses on inspection of the MS4 and documentation.
Within the Town of Valdese only employees who are certified are allowed to administer herbicides and fertilizers.
Contracted personnel administer pesticides. BMP 54 focuses to ensure all staff using pesticides (if staff decides to change
practice), herbicides, and fertilizers are officially certified and following appropriate (minimal) usage. BMP 55 focuses on
tracking certification, as well as, the copies of permits of both municipal staff and contractors.
The Town of Valdese has a small fleet of vehicles and equipment. BMP 56 focuses on the washing side of the problem,
addressing training, protocol, requirements, and options for municipal vehicle operators. BMP 57 focuses on the other
side of the issue, ensuring that vehicle maintenance facilities are correctly disposing of waste and that permitting is
correctly followed to ensure MS4 compliance
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 53
II.G.2.i addresses inconstant/lacking training for municipal employees in regards to good housekeeping and pollution
practices. This is addressed in: 46.B.5, 47.B.4, 49.B.1 BMP 53.B.5, 54.B.1, 56.B.2, 57.b.3, 61.b.1, and 45.b.1. Each of
these BMPs focusing on each of the 7 programs required by the permit.
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
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.
Applicable 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.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 54
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.
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 and Inspections
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
1. Establish: standard
operating procedures
for municipal facility
inspections, a schedule
of inspections, and a
standard for report
documentation/trackin
g.
1. Permit Year 1 1. Were procedures
established? Yes, No;
Status;
Date procedures
established;
Was an inspection
schedule established?
Date of schedule
establishment.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 55
Table 21: Pollution Prevention and Good Housekeeping BMPs
completed per the SPCC
requirements.
As an inventory of municipally
owned facilities with stormwater
pollution potential already exists,
any new municipal facilities built
during the permit cycle will be
evaluated and added to the list
after the facilities completion.
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.
3. 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.
3. Annually
Permit Years 1-5
3. Number of
corrective actions
taken
(SPCC permitted
facilities and non-
SPCC facilities).
4. Train municipal
facility staff on proper
stormwater awareness
and good
housekeeping
methods.
4. See BMP 49
4. See BMP 49
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 56
Table 21: Pollution Prevention and Good Housekeeping BMPs
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
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.
Previously the Town of Valdese
utilized an overall spill procedure
plan – the facility specific spill
response procedure plans will be
written to ensure that facility
specific pollutants are handled
correctly.
1. Develop a written
spill response
procedure plan for
each facility that
requires one.
1. Permit Year 1
1. Were the procedures
created for all facilities
that require one Yes,
No; Status Summary.
2. Implement the spill
response procedures
plan (per facility).
2. Continuously
Permit Years 2-5
2. Number of spill
response plans
implemented.
3. Maintain spill
response procedures in
response to problems
that may arise from
implementation of spill
procedures.
3. Annually
Permit Years 1-5
3. Number of spill
response procedure
plans that required
revisions.
4. Train facility staff
on spill response
procedures.
4. See BMP 49
4. See BMP 49
5. 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.
5. Continuously,
Permit Years 1-5
5. Number of non-
reportable spills;
Number of spills
reported to DEQ.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 57
Table 21: Pollution Prevention and Good Housekeeping BMPs
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
A written O&M plan for
maintaining the Town’s
stormwater conveyances will be
redeveloped and expanded from
the standard operating procedures
previously found under PPGH-6
in the Valdese 2013 SWMP.
The Town of Valdese utilizes a
“Vac-truck” to periodically clean
debris/build up from storm drains.
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
Plan must also be submitted to
DEQ for approval.
1. Develop a written
O&M plan to define
the required
procedures to schedule
inspections, perform
maintenance and
evaluations of the
stormwater collection
system. The plan shall
cover inspection
schedules, standard
documentation, and
staff responsibilities.
This written plan will
build upon the in-
place SOP’s to enable
more consistent
documentation and
will more clearly
define the procedures
already in place.
1. Permit Year 1
1. Was the MS4 O&M
Plan developed: Yes
or No, Status.
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
written O&M Plan
(See BMP 50 & 51).
4. Continuously,
Permit Year 2-5
4. Number of MS4
inspections completed.
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 58
Table 21: Pollution Prevention and Good Housekeeping BMPs
49. MS4 Training
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. The schedule and
procedures for the inspections will
be defined in the town’s O&M
plan (BMP 48).
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; Total
Road miles of
roadside/ROW
conveyances inspected
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 Town so
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
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
Page 59
Table 21: Pollution Prevention and Good Housekeeping BMPs
chooses to do so. The town will
utilize public works resources to
maintain the MS4 infrastructure;
or the issue will be included in the
Towns 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 Towns municipal
SCMs will be kept up to date.
However, at the time of
developing this SWMP the Town
does not currently have a
municipally owned SCM. Should
the Town of Valdese need to
install one following expansion,
these procedures will be followed.
1. Maintain an
inventory of
existing Town-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 Town-owned
SCM.
2. Continuously
2. Were any
municipal SCM
O&M’s developed?
Yes, No; Status.
3. Review/Update
SCM inventory as
necessitated
by new Town
development.
3. See BMP 53
3. See BMP 53
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December 7, 2020
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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.
However, at the time of
developing this SWMP the Town
of Valdese does not currently
have a municipally owned SCM.
Should the Town 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.
Use aerial photography
in conjunction with
Town records to
determine SCM
location/ ownership.
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.
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
DRAFT NCS000488 SWMP
Town of Valdese
December 7, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
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 Town
of Valdese will continue to only
allow approved/certified staff
trained to apply pesticides,
herbicides, and/or fertilizers.
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. Maintain 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.
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Town of Valdese
December 7, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
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.
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.
Wash water can be directed to the
sanitary sewer or to vegetated
areas. Where cleaning operations
cannot be performed as described
above and when operations are
performed in the vicinity of a
storm drainage collection system,
the drain is to be covered with a
portable drain cover during
cleaning activities. Any excess
standing water shall be removed
and properly handled prior to
removing the drain cover. OR
another acceptable method is
installation of a SCM to capture
and treat the wash water runoff.
1. Establish Standard
Operating Procedure
for containing and
disposing of vehicle
and equipment wash
water. The procedures
will be defined
through the facilities
O&M plan.
1. See BMP 45
1. See BMP 45
2. Provide routine
vehicle pollution
prevention training to
staff.
2. See BMP 49
2. See BMP 49
3. Wash all municipal
light vehicles, Town
emergency vehicles,
and equipment using
an established method
listed under this BMP,
or utilize a commercial
carwash facility that
contains and treats
wash water where
applicable.
3. Continuously
Permit Years 1-5
3. Number of vehicle
washings performed;
Was vehicle washing
completed per this
BMP? Yes, No; Status;
Provide quarterly
invoices from
commercial carwash if
utilized.
4. Record washing
procedures. Upon
facility inspection
(BMP 46) verify that
documentation is being
kept ensuring
compliance and said
documentation shows
the facility is
following the best
management practices
defined in their O&M
plan.
4. See BMP 46 4. See BMP 46
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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 Town
has obtained a NPDES
industrial permit for all
subject municipal
facilities/operations.
1. Permit Years 1
1. Log of industrial
permit/s and status.
2. Perform waste
inspections during
facility inspections
(See BMP 46).
2. See BMP 46
2. See BMP 46.
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.
Street/curb and gutter cleaning is
a regular operation task for the
Town. The miles swept by the
street sweeper will be documented
and reported annually.
1. Street/curb and
gutter sweeping is a
regular operational
task that is performed.
1. Continuously
Permit Years 1-5
1. Total number of
lane miles ran by the
street sweeper.
2. Develop and
distribute educational
flyers regarding street
runoff pollution to
help supplement street
cleanings.
2. Continuously
Permit Years 1-5
2. Number of street
pollution flyers
distributed.
59. Litter Management
Collect litter in public areas and
parking lots to reduce negative
impacts on water quality.
1. Remove litter from
Downtown
streets/sidewalks and
empty public waste
receptacles three times
per week or as needed.
1. Continuously
Permit Years 1-5
1. Number of full time
employees
responsible;
Number of trash bags
used.
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2. Collect litter from
public right-of-ways
outside of Downtown
on an as-needed basis
utilizing available staff
or community
volunteers.
2. Annually
Permit Years 1-5
2. Number of litter
pick up events;
Weight of trash
collected/disposed of
for each event
(pounds);
Number of staff and/or
volunteers.
60. Leaf Collection
Implement measures to control
leaves and debris within the
municipal Town limits (to include
all properties). Leaves and yard
waste are collected by the Town
on a weekly basis throughout the
year.
1. Collect leaves
utilizing a vacuum
truck and record the
amount collected on a
continuous basis
throughout the year.
1. Continuously
Permit Years 1-5
1. Number of cubic
yards 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.