NCS000480_Rutherford College Draft Final SWMP_20201214

Draft Stormwater Management Plan
Town of Rutherford College
NCS000480

December 14, 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 .......................................................................................................................... 9
3.4 MS4 Interconnection ..................................................................................................................... 9
3.5 Total Maximum Daily Loads (TMDLs) ..................................................................................... 10
3.6 Endangered and Threatened Species and Critical Habitat .......................................................... 11
3.7 Industrial Facility Discharges ..................................................................................................... 11
3.8 Non-Stormwater Discharges ....................................................................................................... 12
3.9 Target Pollutants and Sources ..................................................................................................... 13

PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 17
4.1 Organizational Structure ............................................................................................................. 17
4.2 Program Funding and Budget ..................................................................................................... 19
4.3 Shared Responsibility ................................................................................................................. 19
4.4 Co-Permittees .............................................................................................................................. 21
4.5 Measurable Goals for Program Administration .......................................................................... 21

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 23

PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 29

PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 32

PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................... 42

PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 45

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ...................... 57

List of Tables

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

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PART 1: INTRODUCTION

The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which
the Town of Rutherford College 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 Rutherford College
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 NCS000480, 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 Rutherford College and
located within the corporate limits of the Town of Rutherford College.

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

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

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PART 2: CERTIFICATION

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

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

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

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

Signature:

Name: Kenneth Geathers

Title: Town Manager

Signed this ____ day of ___________ 20____.

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PART 3: MS4 INFORMATION

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

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3.2 Existing MS4 Mapping
The current MS4 mapping includes all required elements for compliance. Below are a series of maps that
show the locations of the catch basins, junction boxes, and drainage manholes within the City Limits.
(Reference BMP 19).

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The following set of maps show the direction of flow and the major outfalls within Rutherford College
Town limits. Further mapping is outlined in BMP 19.

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Table 1: Summary of MS4 Mapping
Percent of MS4 Area Mapped 90 %
No. of Major Outfalls* Mapped 29 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 Rutherford College 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
n/a
Hoyle Creek 11-45-(0.5 &
2)
WS-IV, CA n/a
Island Creek 11-46-(0.5) WS-IV, CA n/a
Smith Branch 11-46-1 WS-IV n/a

3.4 MS4 Interconnection
The Town of Rutherford College MS4 is interconnected and directly receives stormwater from the Town
of Valdese MS4 (reference BMP 19); however the Town of Rutherford College MS4 does not directly
discharge stormwater into another MS4.

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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 within approved TMDL municipalities.

Table 3: Summary of Approved TMDLs
Water Body Name TMDL Pollutant(s) Stormwater
Waste
Load
Allocation
(Y/N)
Water
Quality
Recovery
Program
(Y/N)
N/A N/A N N

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

Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Scientific Name Common name Species Group Federal Listing
Status
Glyptemys
muhlenbergii
Bog Turtle Vertebrate T (S/A)
Glaucomys sabrinus
coloratus
Carolina northern
flying squirrel
Vertebrate E
Myotis septentrionalis Northern long-eared
bat
Vertebrate T
Corynorhinus
townsendii
virginianus
Virginia big-eared bat Vertebrate E
Alasmidonta varicosa Brook floater Invertebrate ARS
Ophiogomphus
edmundo
Edmons’s Snaketail Invertebrate ARS
Macromia margarita Margarita River
skimmer
Invertebrate ARS
Microhexura
montivaga
Spruce-fir moss
spider
Invertebrate E
Hexastylis naniflora Dwarf-flowered
heartleaf
Vascular Plant T
Liatris helleri Heller's blazing star Vascular Plant T
Hedyotis purpurea
var. montana
Roan Mountain Bluet Vascular Plant E

3.7 Industrial Facility Discharges
The Town of Rutherford College 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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Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number Facility Name
NCG170393 Aquafil O’Mara Inc.
NCGNE0258 BSN-Jobst, Inc.

3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the Town of Rutherford
College as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do
not significantly impact water quality. The Town of Rutherford College 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 Department of Environmental Quality has not required that other non-stormwater flows be
specifically controlled by the Town of Rutherford College.

Wash water associated with car washing that does not contain detergents 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 Rutherford College to determine
whether they may significantly impact water quality. The Town of Rutherford College 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
Dechlorinated swimming pool discharges Incidental
Street wash water Possible
Flows from firefighting activities Incidental

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3.9 Target Pollutants and Sources

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 it. In addition, the Town of Rutherford College has evaluated schools,
homeowners, construction sites 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: Illegal dumping has occurred within the Town.
Cases general residential dumping have been noted by Town employees. 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. The dumping has
been found typically road side but also in secluded urban areas.
Sediment: Previous installed erosion control measure have been removed or fallen
Sediment buildup is largely attributed to mismanaged construction sites with fallen or incorrectly installed
sediment fences. It has been noticed in both reports from citizens and by code enforcement officers that
there are several cases of construction sites not maintaining their erosion control fences during work. 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
Rarely, it has been 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: Restaurants could possibly empty grease traps or not obtain a grease trap.
The Health Department has reported restaurants not maintaining, or even owning, grease traps. This has
led to cases of the restaurants either illegally dumping the grease or allowing the grease to drip onto

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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 water bodies with an influx of water
insoluble grease going down the storm drain.
Chemicals: Totes have been noted in industrial areas, which could pose a risk.
Town staff have noticed containers within manufacturing facilities that have unmarked chemicals. The
totes are unlabeled 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.
Animal Operations/Urban Farming: 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.
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. If a septic tank is leaking, it can overwhelm the natural processes
of the soil (infiltration) leading to nutrient overload in streams fed by groundwater, or allowing pathogens
to enter, increasing the risk of disease.
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 Illicit Discharge & Detection Elimination (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 303(d)
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.

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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 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.
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. This problem has been noticed by municipal waste managers and is
difficult to track as often the improper disposal waste is mixed in with the standard refuse. Other
examples include grease going down sinks clogging 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 Commercial/Bona fide Farms/Urban
Farming
Illicit Discharge
Public Education & Outreach
Underground Storage Tanks Business and Residents Illicit Discharge
Public Education & Outreach
Illicit Discharges General Public, Businesses,
Municipal Employees
Illicit Discharge
Public Education & Outreach
Good Housekeeping
Illegal Dumping and
Improper Disposal of Waste
General Public, Businesses,
Municipal Employees
Illicit Discharge
Public Education & Outreach
Good Housekeeping

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PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION

4.1 Organizational Structure
The Town of Rutherford College has contracted Western Piedmont Council of Governments (WPCOG)
to coordinate Stormwater Management Plan development/writing efforts, to ensure the Town is
facilitating Best Management Practices to protect water quality. The Town of Rutherford College will be
the primary operator of this stormwater program. Staff will be trained in handling internal procedures and
reports of stormwater issues/violations. WPCOG be implementing the Public Education & Outreach, and
the Public Involvement & Participation on behalf of the Town. 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 Program
Administrator.

Table 8: Summary of Responsible Parties
SWMP Component Responsible Position Staff Name Department
Stormwater Program
Administration
Town Manager Kenneth Geathers Administration, Town
of Rutherford College
SWMP Management WPCOG Senior
Planner/Natural
Johnny Wear WPCOG, Community
and Regional Planning

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Public Education &
Outreach
WPCOG Senior
Planner/Natural
Resources
Administrator
Johnny Wear WPCOG, Community
and Regional Planning
Public Involvement &
Participation
WPCOG Senior
Planner/Natural
Resources
Administrator
Johnny Wear WPCOG, Community
and Regional Planning
Illicit Discharge
Detection &
Elimination
Illicit Discharge Officer Todd Justice
Patrick DeMauro
WPCOG, Community
and Regional Planning
Construction Site
Runoff Control
N/A N/A NCDEQ – Asheville
Regional Office
Post-Construction
Stormwater
Management
Stormwater
Administrator
Jack Cline WPCOG, Community
and Regional Planning
Pollution
Prevention/Good
Housekeeping for
Municipal Operations
Stormwater
Administrator
Jack Cline WPCOG, Community
and Regional Planning
Municipal Facilities
Operation &
Maintenance Program
Stormwater
Administrator
Jack Cline WPCOG, Community
and Regional Planning
Spill Response Program Utility Director

Stormwater
Administrator
John Leger

Jack Cline
Town of Rutherford
College Public Works
WPCOG Community
and Regional Planning,
Volunteer/Town Fire
Department, if
applicable
MS4 Operation &
Maintenance Program
Utility Director John Leger Town of Rutherford
College Public Works
Municipal SCM
Operation &
Maintenance Program
Utility Director

Stormwater
Administrator
John Leger

Jack Cline
Town of Rutherford
College Public Works

WPCOG Community
and Regional Planning
Pesticide, Herbicide &
Fertilizer Management
Program
Utility Director John Leger Town of Rutherford
College Public Works

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Vehicle & Equipment
Cleaning Program
Utility Director John Leger Town of Rutherford
College Public Works
Pavement Management
Program
Utility Director John Leger Town of Rutherford
College Public Works

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

As mentioned previous, WPCOG was contracted to write the Town of Rutherford College’s Stormwater
Management Plan, for a rate of $8,000.00. Also, the Town has a one-year contract (which will need to be
modified, adopted, and signed every year) with Western Piedmont Council of Governments for the
following services: Public Education & Outreach Program and Public Involvement & Participation
Program. The current one year contract (July 1, 2019 and ending June 30, 2020) amount is $2,845.00.

The Town of Rutherford College will be using Town staff, and on occasion West Consultants, to
implement Illicit Discharge Detection and Elimination Program, Post-Construction Site Runoff Control
Program, and Pollution Prevention and Good Housekeeping Programs. The Town has allocated
$11,500.00 toward this effort.

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 help offset this cost to the town. The Town reserves the right to apply stormwater
utility fees to supplement stormwater management costs; these fees would be collected by the Town
through tax or utility bills. The goal would be for the funds collected to support the stormwater program
through stream repairs and other water quality efforts.

Should the Town of Rutherford College choose not to renew the existing one-year contract with WPCOG,
prior to the last month, a revision to the existing NPDES permit and Stormwater Management Plan would
need to occur. The Town of Rutherford College would be required to renew the one-year contract for five
years straight to fully carry out the 5 year NPDES permit cycle. Any changes to the partners or measures
in this document will need to be reviewed and approved by NCDEQ.

4.3 Shared Responsibility
Beginning July 2019, the Town of Rutherford College will be responsible to implement the following
minimum control measures, with the aid of WPCOG (entity), which are as stringent as the corresponding
NPDES MS4 Permit requirement. The Town of Rutherford College 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 Rutherford College, nor the other entity fully performs the permit obligation. Table 9
below summarizes individual responsibilities for each program.

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Table 9: Shared Responsibilities
SWMP BMP or
Permit Reference Implementing Entity & Program Name
Legal
Agreement
(Y/N)
General Requirements Town of Rutherford College N
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
West Consultants PLLC
Y
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
NCS000480 for the Town of Rutherford College.

4.5 Measurable Goals for Program Administration
Referencing, MS4 Inspection Report for the Town of Rutherford College - Program Implementation,
Documentation & Assessment, Permit Citation - II.A.2. Stormwater Plan Implementation & Evaluation,
II.A.3. Keeping the Stormwater Plan Up to Date, II.A.4. Availability of the Stormwater Plan, II.A.5.
Stormwater Plan Modifications and II.A.7 Written Procedures; the Town has not evaluated the
performance and effectiveness of the program and has not develop any procedures for doing so. In order
to meet the State requirements for this section, a self-assessment of the effectiveness of the program
components will be completed annually. Written procedures, otherwise known as, the Stormwater
Management Plan: SWMP update, has been drafted, but not adopted at this time. The SWMP will be
adopted during Permit Year One of the NPDES permit cycle following acceptance of the SWMP and
issuance of the NPDES permit. Included in the SWMP the Town will be required to establish written
agreements with entities that are performing work on the Town’s behalf (II.A.6.).

MS4 Inspection Report for the Town of Rutherford College - Program Implementation, Documentation &
Assessment, Permit Citation - III.A. Program Documentation; the Town maintained some documentation
regarding inspections, but no other aspect of the program components. There was an overall lack of
documentation relating to the Town’s stormwater program (e.g., no documentation for inspections,
maintenance activities, or educational programs).

MS4 Inspection Report for the Town of Rutherford College - Program Implementation, Documentation &
Assessment, Permit Citation - III.B. Annual Report Submittal: MS4 annual reports have not been
submitted. Further, no fiscal analysis was provided (Permit Citation - IV.B). Within the below BMPs
Annual Report are a required submittal that will occur on August 31st each permit year and will include
all applicable parts of the NPDES MS4 permit.

The Town of Rutherford College will manage, document, 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

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Table 11: Program Administration BMPs
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
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.

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Town of Rutherford College
December 14, 2020
Page 22

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The Town of Rutherford College will implement a Public Education and Outreach Program (developed
by and programs ran by WPCOG) to distribute educational materials to the community or conduct
equivalent outreach activities about the impacts of storm water discharges on water bodies and steps the
public can take to reduce pollutants in storm water runoff.

In reference to MS4 Permit Self Audit Report - Public Education and Outreach, Permit Citation II.B.2.a
Program Requirements, II.B.2.c. Target Audiences, and II.B.2.h. Public Education and Outreach
Program: The Town of Rutherford College had not defined goals & objectives for community wide
issues. Stormwater impact target audiences and extend of exposure had not been recorded at public
education and outreach events.

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
Rutherford College 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 Commercial, Bona fide Farms and/or 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 WPCOG (on behalf of the Town of Rutherford College) 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

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Table 13: Public Education and Outreach BMPs
3. Stormwater Fliers
Continue to utilize the WPCOG
stormwater outreach program to
develop new educational
materials to be distributed at
events, at the nearest county
library (Valdese Public Library,
refilled annually or as required),
and/or through mailers to utility
bill addresses. Five topics will be
addressed over the term of the
permit; general stormwater
awareness, illicit discharges,
illegal dumping, chemicals and
proper disposal of waste.

1. Develop and
distribute new fliers to
raise general
stormwater awareness.
1. Permit Year 1

1.-5. Number of flyers
distributed at each
event;

Number of flyers left
for distribution at
Library; Number of
flyers remaining when
refilled

Number of fliers sent
through the mail.
2. Develop and
distribute new fliers
educating about illicit
discharges.
2. Permit Year 2

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. These
flyers shall focus on
educating how to
reduce nutrient loads
from residential and
business landscaping.
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

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Town of Rutherford College
December 14, 2020
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Table 13: Public Education and Outreach BMPs
Provide stormwater educational
information to the citizens
through outreach activities at
community events. The Town will
maintain its outreach booth at the
annual Fall Festival to provide
educational materials and to raise
awareness of stormwater issues.
WPCOG will staff the booth on
behalf of the Town per their
outreach agreement.

COVID-19 has limited outreach
opportunities at public events due
to their cancelation in 2020. As
such, alternative ways for this
type of outreach will be
necessary. Alternatives such as
booths at farmers markets and/or
a booth inside the library (if open)
can provide these opportunities
while still being safe for
participants.
1. Staff will have
continue to have a
booth at the annual
Fall 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 annual Fall
Festival.

2. Staff will provide
alternative outreach
opportunities if the
Fall 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 (burke county
or sawmills farmers
markets), or other
events if they are still
available at different
times throughout the
year.
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
classrooms, workshops, and
hands-on activities related to
stormwater best practices.

COVID-19 has limited outreach
opportunities at schools and
1. WPCOG 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.

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December 14, 2020
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Table 13: Public Education and Outreach BMPs
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
2. WPCOG will
conduct stormwater
related workshops that
include teachers who
work with Rutherford
College 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
The WPCOG will design new
printed materials for target
audiences to aid stormwater
education. The Town will
continue to distribute these
materials at outreach events,
1. Staff will create new
printed materials for
distribution that
addresses stormwater
best management
practices.
1. See BMP 3 1. See BMP 3

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December 14, 2020
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Table 13: Public Education and Outreach BMPs
available at Town hall, and
through utility bill mailers.
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 Rutherford College
stormwater web page
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.

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Table 13: Public Education and Outreach BMPs
8. Evaluate Pollutants Sources and Audiences
Reevaluate 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.

1. Reevaluate 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 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

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December 14, 2020
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Table 13: Public Education and Outreach BMPs
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
Update and maintain the already
established webpage designed to
convey information about the
stormwater program. The Town
webpage will: convey the
importance of stormwater quality,
provide educational resource
links, compliant procedures,
stormwater regulations,
stormwater permit information,
good housekeeping information,
ands shall host the current
SWMP, stormwater ordinance,
and annual report.

1. The Town will
maintain and update
the 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 also post the
current SWMP,
stormwater ordinance
and that permit years
annual assessment.
1. Annually,

Permit Years 1-5

1. Was annual self-
assessment uploaded
to the Town of
Rutherford College’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
3. Provide education
during the illicit
discharge enforcement
process.
3. Continuously,

Permit Years 1-5
3. Number of citizen
interactions during
enforcement.

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December 14, 2020
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Table 13: Public Education and Outreach BMPs
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 Rutherford College
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 default
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.
5. Publicize contact
information on the
Town webpages as
well as the Town of
Rutherford College
Facebook page.
5. Continuously,

Permit Years 1-5

5. Number of hotline
calls received overall.

DRAFT NCS000480 SWMP
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December 14, 2020
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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, II.C.2.b. Mechanism for Public Involvement, and
II.C.2.c. Hotline/Help Line: The Town plans to grow that effort in the future. Proximity to Lake
Rhodhiss provides opportunity for public interest in events. The Town of Rutherford College will
establish a hotline, webpage reporting form and survey/s, along with the use of the existing WPCOG
Water Resource Committee to gather public input. Stream clean-ups will be completed on an annual
basis. All events, programs, and public forums will be announced through social media.

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 Rutherford College will manage, implement and report 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 Email Reporting
Continue to provide a mechanism
for public input via the Rutherford
College stormwater email for
reporting stormwater issues and
allowing for input regarding the
stormwater program.
1. Maintain the
stormwater email
complaint/reporting/in
put contact
information on the
Towns website.
1. Continuous,

Permit Years 1-5

1. Did the email need
to be updated? Yes,
No; Status

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Table 14: Public Involvement and Participation BMPs
2. Continue to use the
Rutherford College
stormwater email to
record and track
responses, inputs,
issues, and concerns
for metric reporting
2. Continuous,

Permit Years 1-5

2. Number of
questions, reports, and
comments submitted
via the stormwater
email;
Purpose of each
question, report, or
comment.
15. Social Media Outreach – Event Promotion
Utilize the existing Town of
Rutherford College 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 Rutherford
College 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 provide general
stormwater awareness.
1. Continuously

Permit Years 1-5

1. Total Number of
posts on the Town of
Rutherford College
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.

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December 14, 2020
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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 linked to
on the Towns website
once a year. The
survey will be open to
feedback for a total of
4 weeks. The survey
will also be shared on
the Towns Facebook
page.

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

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December 14, 2020
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Table 14: Public Involvement and Participation BMPs
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.

For the Town of
Rutherford College,
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.
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 NCS000480 SWMP
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December 14, 2020
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PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
MS4 Inspection Report for the Town of Rutherford College – Illicit Discharge Detection and Elimination
(IDDE), Permit Citation II.D.2.a. IDDE Program: The Town is regulated by the water supply watershed
protection ordinance, which does not contain any specific language on the application of notice of
violations. Written procedures for implementing an IDDE Program have not been completed. In response
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 will also, in responses to, MS4 Inspection Report for the Town of Rutherford College – Illicit
Discharge Detection and Elimination (IDDE), Permit Citation II.D.2.b. Legal Authority, the Town will
create, adopt, maintain and enforce a stormwater ordinance and other regulatory mechanisms that provide
the legal authority to prohibit illicit connections and discharges to the MS4.
The Town maintained a map, but the major outfalls were not identified at time of audit. Since the audit
was complete, the Town hired West Consulting to map all outfalls, inlets, basins, and flow direction
(II.D.2.c. Storm Sewer System Map). In the future the Town will continue to update the MS4 map as new
development occurs (Permit Ref: 3.4.1 BMP 19).
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. Data such as date
screening occurred, location of inspected outfall, and photos of outfall will be recorded in GIS.
The Town of Rutherford College Stormwater Management Plan outlines the response authority, but not
procedures (II.D.2.e.). Due to water supply watershed not identifying notice of violation procedures, the
Town of Rutherford College issued no NOVs. Currently, there is not a way to track and document
investigations (II.D.2.f. & j.).Within the new permit cycle, as stated below, the Town will be adopting an
IIDE Plan to establish written procedures. A chart will be used to track and document IDDE cases. 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 discharge and illegal
dumping through the use of educational outreach materials and training opportunities. Previously, no
training had been administered to employees (II.D.2.g.). Information to the public was provided in bill
inserts on a regular basis (II.D.2.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 can be report through a webpage portal; however the line of
communication was not publicized (II.D.2.i). The stormwater hotline phone number, as mentioned in the
public education and outreach and illicit discharge areas of this plan.
The Town of Rutherford College 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.

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December 14, 2020
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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. Addition of Major Outfalls and Continual Updates to MS4 Map
The Town will contract with West
Consultants once a year to Update
and maintain the existing
municipal storm sewer system
map showing the infrastructure
and conveyances for managing
stormwater runoff from the Town.
West Consultants will be
contracted to continue to maintain
the Town of Rutherford Colleges
MS4 map. Per the 2019 MS4
audit, major outfalls will be added
to the existing MS4 map along
with its regular maintenance.
1. Identify and add
major outfalls, and
number of major
outfalls to the existing
MS4 map
1. Permit Year 1

1. Were outfalls added
to the MS4 map? Yes,
No; Status;

Report number of
major outfalls
identified.

2. When new
conveyances and/or
outfalls are located or
constructed, add new
infrastructure to the
existing map; to be
updated on an annual
basis.
2. Annually

Permit Years 1-5

2. Were revisions to
the MS4 map
required? Yes, No;
Status.

Number of outfalls
identified/constructed

Number of Outfalls
added 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
1. Redevelop and
Update the existing
Illicit Discharge and
Elimination ordinance.
Adoption of the
updated ordinance will
be done through
council approval.
1. Permit Year 1

1. Was the IDDE
ordinance updated?
Yes, No; Status;

Date ordinance was
adopted..

DRAFT NCS000480 SWMP
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December 14, 2020
Page 36

Table 15: Illicit Discharge Detection and Elimination BMPs
The Town will update the existing
IDDE ordinance 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. This update shall
include further definition of the
issuance of NOVs (per the audit)
and bring the IDDE ordinance up
to current standard.

2. Review the
ordinance and update
if revision is required.
Revisions will require
council reapproval.
This annual review
will begin follow the
ordinances update in
permit year 1.
2. Annually

Permit Years 2-5

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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 37

Table 15: Illicit Discharge Detection and Elimination BMPs
Update and implement the written
IDDE Plan to define the
procedures for detecting and
addressing illicit discharges,
illegal dumping and any non-
stormwater discharges identified
as significant contributors of
pollutants to the MS4. Previously
the Town of Rutherford College
had IDDE standard operating
procedures included in prior
stormwater plans, the new written
IDDE plan will build upon those
and further define the IDDE
standard operating procedures.
1. Develop an updated
written IDDE Plan to
further define the
procedures of
identifying, tracking
and processing illicit
discharges, illegal
dumping and
significant contributors
of pollutants to the
MS4. The plan shall
build on the existing
IDDE program to
better define the
processes of IDDE
enforcement and the
issuance of NOV’s.
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 approved 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
1. Use MS4 map to
locate outfalls near
high pollution risk
areas.

1. Permit Year 1

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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 38

Table 15: Illicit Discharge Detection and Elimination BMPs
pollution potential: Areas with
known dry weather outfall
flows/violations, repeat offenders,
business/commercial areas,
industrial areas, and businesses
with high pollution potential.
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.
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 procedures
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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 39

Table 15: Illicit Discharge Detection and Elimination BMPs
Implement the IDDE Plan to
detect and address illicit
discharges, illegal dumping and
any non-stormwater discharges
identified as significant
contributors of pollutants to the
MS4.
1. Screen priority areas
likely to have illicit
discharges (BMP 22).
1. Annually,

Permit Years 1-5

1. Number of illicit
discharges found in
priority areas.

2. Investigate and
Enforce IDDE issues.
2. See BMP 26

2. See BMP 26
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. Establish a
list/documentation
procedure for tracking
illicit discharge
connections and illegal
dumping violations,
outlining who made
the complaint, location
of violation, note prior
offenses, status and
action taken.
1. Permit Year 1

1. Was IDDE tracking
list created? Yes, No;
Status;

Date tracking list was
made.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 40

Table 15: Illicit Discharge Detection and Elimination BMPs
Staff will create and maintain the
mechanisms for tracking and
documenting the date(s) an illicit
discharge, illicit connection or
illegal dumping was observed,
the results of the investigation,
any follow-up of the
investigation, the date the
investigation was closed, the
issuance of enforcement actions,
and identifying chronic violators.
2. Track illicit
discharge/connection
and illegal dumping
reports/investigations
utilizing the IDDE
tracking
documentation/list

The list will
differentiate staff
discovery from citizen
reporting to allow for
review of the outreach
program.
2. Continuously,
following
establishment in
Permit Year 1.

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.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 41

Table 15: Illicit Discharge Detection and Elimination BMPs
5. Evaluate and assess
the IDDE
documentation –
Identify where
improvement can be
made based on data
collected, problems
encountered and
needs. Evaluation 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 tracking
documentation
needed? Yes, No;
Status.
Permit
Ref.
3.4.5: Staff IDDE Training
Measures to provide training for municipal staff and contractors who, as part of their normal job
responsibilities, may come into contact with or otherwise observe an illicit discharge, illicit connection or
illegal dumping. Training shall include identifying and reporting illicit discharges, illicit connections and
illegal dumping. Each staff training event shall be documented, including the agenda/materials, date, and
number of staff participating.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
27. Staff Training
Train municipal staff and
contractors to identify and report
illicit discharges, illicit
connections, illegal dumping and
spills.
1. Identify staff
members and/or
contractors that are
likely to observe an
illicit discharge, illicit
connection and illegal
dumping.
1. See BMP 11

1. See BMP 11

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 42

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

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

2. Utilizing the Towns
social media and
website, 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
1. Utilize the hotline
(BMP 12) to receive
IDDE reports.
1. See BMP 12

1. See BMP 12

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 43

Table 15: Illicit Discharge Detection and Elimination BMPs
discharges, illegal dumping, and
spills.
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 website and
shared via the
Rutherford College
Facebook account.
3. See BMP 12

3. See BMP 12
30. IDDE Email Online Reporting
The Town will continue to utilize
the Rutherford College
Stormwater reporting email for
receiving IDDE reports/input.
1. Continue to utilize
the Rutherford College
Stormwater email for
receiving IDDE
reports/input.
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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 44

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

Permit Years 1-5

2. Average response
time.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 45

PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the Town of Rutherford College 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
2
The Town of Rutherford College also implements 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 NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 46

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 on the
Towns website.
2. See BMP 17

2. See BMP 17
3. Utilize reporting
email (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
stormwater email on
the Towns website and
Facebook Page.
4. See BMP 14

4. See BMP 14
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
1. Develop an
ordinance that
addresses construction
site waste.
1. Permit Year 1

1. Ordinance
developed: Yes or No,
Status.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 47

Table 17: Construction Site Runoff Control BMPs
Require construction site
operators to control waste at the
construction site that may cause
adverse impact to water quality.
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 NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 48

PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
MS4 Inspection Report for the Town of Rutherford College – Post-construction Site Runoff Control
Program Implementation Status, Permit Citation: Currently, the Town does not have a mechanism in
place to require deed restrictions and protective covenants. Within the ordinance established in Permit
Year One enabling language granting the Town of Rutherford College the ability to require deed
restrictions and protective covenants (II.F.2.e.) will be included.

An inventory of projects will be kept and proactive inspections will be administered by Staff semi-
annually. A private engineer will certify each SCM annually to ensure 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 spreadsheet to record enforcement action to obtain compliance (II.F.2.i.).

MS4 Inspection Report for the Town of Rutherford College – Post-construction Site Runoff Control
Program Implementation Status, Permit Citation: II.F.3.c. Nutrient Sensitive Waters: The Town had not
designed or constructed any SCMs in the permitted area specifically to reduce nutrient loads.

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 Rutherford College and discharge into the MS4. These elements
are designed to minimize water quality impacts by 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 Rutherford College 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)

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 49

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 50

The Town of Rutherford College has existing requirements including the presence of a Qualifying
Alternative Program(s) in all of the Town limits. The Qualified Alternative Program is the Lake
Rhodhiss water supply watershed Critical Area WS-IV and Protected Area WS-IV. To ensure
compliance with the NPDES MS4 Phase II post-construction program requirements the Town of
Rutherford College applies the post-construction standards throughout the Town Limits, including the
area that is located within the water supply watershed. These requirements are to be adopted as local
ordinance(s) per BMP 37.B.1. and implementation per BMP 37.B.3-4, and are summarized in Table 19
below.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 51

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 Chapter 152 Zoning Code Watershed
Protection 152.110
4/5/2010
3.6.3(a) & 15A NCAC
02H.0153(c) Federal, State &
Local Projects
Chapter 152 Zoning Code Watershed
Protection 152.111
4/5/2010
3.6.3(b) Plan Review Chapter 152 Zoning Code Watershed
Protection 152.155-152.122
4/5/2010
3.6.3(c) O&M Agreement Chapter 152 Zoning Code Watershed
Protection 152.124
4/5/2010
3.6.3(d) O&M Plan Chapter 152 Zoning Code Watershed
Protection 152.124
4/5/2010
3.6.3(e) Deed
Restrictions/Covenants
Chapter 152 Zoning Code Watershed
Protection 152.122
4/5/2010
3.6.3(f) Access Easements Chapter 152 Zoning Code Watershed
Protection 152.122
4/5/2010
Permit Requirements for
Inspections and Enforcement
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(b) Documentation Chapter 152 Zoning Code Watershed
Protection 152.126
4/5/2010
3.6.2(c) Right of Entry Chapter 152 Zoning Code Watershed
Protection 152.115
4/5/2010
3.6.4(a) Pre-CO Inspections Chapter 152 Zoning Code Watershed
Protection 152.126
4/5/2010
3.6.4(b) Compliance with Plans Chapter 152 Zoning Code Watershed
Protection 152.126
4/5/2010
3.6.4(c) Annual SCM Inspections Chapter 152 Zoning Code Watershed
Protection 152.126
4/5/2010
3.6.4(d) Low Density Inspections Chapter 152 Zoning Code Watershed
Protection 152.126
4/5/2010
3.6.4(e) Qualified Professional Chapter 152 Zoning Code Watershed
Protection 152.122
4/5/2010
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.6(a) Pet Waste Burke County Animal Control Ordinance
Section 6-1
08/2017
3.6.6(b) On-Site Domestic
Wastewater Treatment
Chapter 51: Sewer Use Regulations 51.020 11/19/1984

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 52

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

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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 53

Table 20: Post Construction Site Runoff Control BMPs
36. Qualifying Alternative Program
The QAP requirements are applicable to the Town of Rutherford College; however the Phase II Post-
construction Stormwater Ordinance is being administered to fulfill both requirements.
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.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 54

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

All required submittals (as
defined by the plan review
procedures) must be received by
the Town 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 Rutherford College
requires the County to hold the
Certificate of Occupancy on all
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

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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 55

Table 20: Post Construction Site Runoff Control BMPs
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.

The Town of Rutherford College
utilizes West Consultants to do
SCM plan review regarding the
structures, but the Town shall
continue to manage the
submittal/documentation part of
the review. The Town collects the
submittal documents and issues
the permit after West Consultants
reviews the SCM and drainage
designs. West Consultants is
recommended to encourage
SCMs that help reduce nutrient
loading to encourage the quality
of nearby water bodies.

3. Maintain the existing
SCM Inventory sheet.
Said sheet tracks 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
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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 56

Table 20: Post Construction Site Runoff Control BMPs
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
41. Inspection and Enforcement

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 57

Table 20: Post Construction Site Runoff Control BMPs
After project completion, but
prior to issuance of a certificate of
occupancy, an inspection will be
completed by a qualified
professional and/or a qualified
representative of the Town 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.

Town of Rutherford College staff
will be responsible for the
municipal inspection of SCMs
annually.

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.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 58

Table 20: Post Construction Site Runoff Control BMPs
Permit
Ref.
3.6.5: Documentation
Measures to maintain adequate documentation and standardized inspection and tracking mechanisms to: (a)
Maintain an inventory of post-construction SCMs and low density projects, (b) Document, track and maintain
records of inspections and enforcement actions. Tracking shall include the ability to identify chronic violators,
and (c) Make available to developers all relevant ordinances, post-construction requirements, design standards,
checklists, and/or other materials.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
42. Documentation – Low Density
Ensure tracking and records are
maintained on low density
projects to ensure that upon
inspection, impervious overages
can be determined, and corrective
actions taken. Ensure
informational materials are
available on the Towns 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.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 59

Table 20: Post Construction Site Runoff Control BMPs
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
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 Towns 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.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 60

Table 20: Post Construction Site Runoff Control BMPs
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.

Almost all the Town of Rutherford
Colleges 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.
1. Develop and adopt
a Pet Waste
Ordinance to reduce
the amount of pet
waste that reaches
receiving water
bodies.
1. Annually

Permit Years 1-5

1. Was the Pet Waste
Ordinance Adopted?
Yes, No; Status.

Date of adoption
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 NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 61

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the
Town of Rutherford College 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
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 Rutherford College 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, Permit Citations II.G.2.a., the Town had
maintained an inventory of municipal facilities, but had not determined which facilities were at risk to
generate polluted stormwater runoff. A list of these possible polluters will be established.

An O & M program for the facilities, SCMs, catch basins and conveyance systems has not be created to
date (II.G.2.b, II.G.2.e, and II.G.2.f.). After the acceptance of the SWMP and in Permit Year One, an O
& M program will be established. (BMP 45). Furthermore, the municipal facilities and SCMs were being
inspected annually, as required per DEQ, but did not include documentation for potential stormwater
impacts (II.G.2.b. and II.G.2.h.). Incorporated in the O & M program, staff will be trained to determine
appropriate operations and maintenance for facilities and SCMs. To date staff had no training in this area.
The Town of Rutherford College staff did not perform street maintenance, including cleaning of catch
basins and stormwater conveyances (II.G.2.e).

II.G.2.d states that "The Town of Rutherford College did not evaluate BMPs based on their pollutant
removal" in reference to streets, roads, and public parking lot maintenance. Several of the BMPs below
address this issue by developing, adopting, and maintaining procedures that focus on pollutant removal in
these impervious areas. Permit Reference: 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.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 62

In the audit, II.G.2.e addresses the prior lack of maintenance of the Town’s storm sewer system, Permit
Reference, 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, BMP 49 trains maintainers on
the correct procedure, BMP 50 focuses on inspection along with its documentation, and BMP 51
addresses the audit problem itself by performing the maintenance on the system with documentation.

Previously, the use of pesticides, herbicides, and fertilizers in municipal facilities was not well tracked or
managed as stated in II.G.2.i. Permit Reference, 3.7.5, BMP 54 focuses to ensure all staff using
pesticides, herbicides, and fertilizers are officially certified and following appropriate (minimal) usage.
BMP 55 focuses on tracking contractor certification as well as the copies of permits of both municipal
staff and contractors.

II.G.2.j. 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.

II.G.2.k. addresses a lack of measures regarding correct waste disposal and cleaning of municipal
vehicles/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.

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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 63

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

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

Permit Years 2-5

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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
Page 64

Table 21: Pollution Prevention and Good Housekeeping BMPs
46. Municipal Facility 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
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.
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.

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

Permit Year 1-5

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

Permit Years 1-5

3. Number of facilities
inspected;

Number of SPCC
permitted facilities
inspected.

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
4. Document and
correct issues found
during inspections. If
a facility is subject to
SPCC requirements,
then ensure the correct
documentation is in
place for compliance
with the
regulation/requirement
s.
4. Annually

Permit Years 1-5

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

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

5. See BMP 49

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

DRAFT NCS000480 SWMP
Town of Rutherford College
December 14, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
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.

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

Malcolm Boulevard is the only
street in Rutherford College that
has a curb and gutter system. As
such preventative maintenance is
already done to clean this state
owned street, it will be included
in the MS4 O&M plan.
1. Develop an 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.
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.

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4. Administer the
O&M Plan (See BMP
50 & 51).
4. Continuously,

Permit Year 2-5

4. Number of MS4
inspections completed.

49. MS4 Training
Provide MS4 training to
municipal and contracted staff to
minimize pollutants in the
stormwater collection system,
prevent unnecessary damage and
wear on the system, increase
awareness of stormwater issues,
and show the procedures on how
to deal with stormwater related
issues.

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

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

Permit Years 1-5

1. Number of trainings
held;

Number of personnel
trained.

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

1. Continuously

Permit Years 1-5

1. Number of catch
basins and
conveyances
inspected; Number of
conveyance issues
found/reported; Miles
of ROW’s inspected
51. MS4 Maintenance

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Table 21: Pollution Prevention and Good Housekeeping BMPs
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
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.
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
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 Rutherford College
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.

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

3. See BMP 53
53. Municipal SCMs
The municipal SCM/s operation
and maintenance program will
ensure the stormwater structures
are being managed/maintained in
a way that does not negatively
impact water quality. The SCMs
will be maintained in a scheduled
and well-defined manner written
in its O&M plan.

At the time of developing this
SWMP the Town of Rutherford
College 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; Total
number of Municipally
owned SCMs
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

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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 only
staff who will be allowed to apply
pesticides, herbicides, or
fertilizers will be certified
individuals who use methods that
minimize the amounts used.

As staff previously took part in
pesticide, herbicide, and fertilizer
trainings, this shall expand to
include contractors that work on
behalf of the Town to ensure only
safe applications are being done.
1. Continue to provide
training to municipal
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.
These trainings will
now include
contractors that work
on behalf of the Town
to ensure all pesticide
applications do not
pose potential
pollution risk.

1. See BMP 49

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

Permit Years 1-5
(FY19/20-FY23/24)

1. Number of certified
personnel.

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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.

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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
57. Vehicle and Equipment Maintenance
The Town of Rutherford College
does not have a facility for vehicle
maintenance as municipal
vehicles/equipment are taken to
local vehicle shops for
maintenance. However municipal
staff will be trained to be aware of
the pollution potential of their
vehicles to minimize the potential
for pollution generation.
1. Provide routine
pollution prevention
and waste management
training to staff.
1. See BMP 49

1. 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. As
the Town of Rutherford College
does not have a regular street
cleaning service, streets will be
swept/cleaned annually. To
1. Street/curb and
gutter sweeping will
be done to reduce road
pollutants in runoff
with a focus on high
priority areas prone to
buildup or higher
chance of conveyance
damage/hinderance.
1. Annually

Permit Years 1-5

1. Total number of
lane miles swept.

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Table 21: Pollution Prevention and Good Housekeeping BMPs
supplement this, an outreach
approach and right of way
conveyances/inlets with frequent
issues will be prioritized.

2. Track
conveyances/inlets that
have frequent
problems with
pollution to prioritize
their maintenance.
2. Continuously

Permit years 1-5
2. Number of high
priority cleanings
done.
3. Develop and
distribute educational
flyers regarding street
runoff pollution to
help supplement street
cleanings.
3. Continuously

Permit Years 1-5
3. 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. Parking lots public
waste receptacles are
emptied on a weekly
basis.
1. Continuously

Permit Years 1-5

1. Number of full time
employees
responsible;
Number of trash bags
used.
2. All other litter
collection is performed
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 and Yard Debris Outreach
Implement measures to reduce the
amount of leaves and debris
entering storm drains within the
Town.

The Town of Rutherford College
does not provide a leaf collection
service, however the company
contracted to collect trash on
behalf of the Town will collect
1. Leaves are disposed
of by individual
property owners.
Leaves collected on
town property will be
bagged and properly
disposed of. The
procedures for their
collection and disposal
will be included in the
facility O&M plans.
1. Continuously

Permit Years 1-5

1. Number of bags of
leaves
collected/disposed of
from municipal
properties

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Table 21: Pollution Prevention and Good Housekeeping BMPs
bagged yard waste at the owner’s
expense.

To supplement this an educational
approach will be taken alongside
including leaf management
procedures in the MS4 O&M plan
(BMP 48) and each facility O&M
plan (BMP 45).

Should issues arise from this
approach, further
measures/revisions to the MS4
O&M plan shall be made to
address said issues.
2. Educational
materials will be
developed and
distributed at Town
Hall to educate the
residents/businesses on
leaf litter and yard
debris impacts on
stormwater quality.
2. Annually

Permit Years 1-5
2. Number of leaf
litter/yard waste flyers
distributed.
3. Review MS4 O&M
Plan (BMP 48). If
leaf/yard debris issues
have arisen, revise
plan to address
shortcomings.
3. See BMP 48 3. See BMP 48
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.

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Table 21: Pollution Prevention and Good Housekeeping BMPs
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.