NCS000604_Cajahs Mtn Draft Final SWMP_20200810

Draft Stormwater Management Plan
Town of Cajah’s Mountain
NCS000###

August 6th, 2020

Table of Contents

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

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

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

PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 13
4.1 Organizational Structure ............................................................................................................. 13
4.2 Program Funding and Budget ..................................................................................................... 15
4.3 Shared Responsibility ................................................................................................................. 15
4.4 Co-Permittees .............................................................................................................................. 17
4.5 Measurable Goals for Program Administration .......................................................................... 17

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 19

PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 26

PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 29

PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ............................................... 3942

PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 42

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ............ 5457

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 Cajah’s Mountain 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 Cajah’s Mountain
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 NCS000xxx, 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 Cajah’s Mountain and
located within the corporate limits of the Town of Cajah’s Mountain.

In preparing this SWMP, the Town of Cajah’s Mountain 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: Ronnie Setzer

Title: Mayor

Signed this __August_ 6th_ of 20___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
Cajah’s Mountain, including all regulated activities associated with the discharge of stormwater from the
MS4. The map below shows the corporate limits of Town of Cajah’s Mountain as of the date of this
document.

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3.2 Existing MS4 Mapping
The current MS4 mapping includes outfalls located within the Town of Cajah’s Mountain. In the future
the Town will be adding the following elements to the map: pipe locations, flow direction, inverts,
ditches, inlets, catch basins, manholes outfall, sizes and conditions (Reference BMP 19).

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The Town of Cajah’s Mountain has a historic count of 22 outfalls per the GIS layer created; however it is
not certain that all of these are major per the definition provided below. The Town will be verifying all
elements as mentioned above in the completion of BMP 19.

Table 1: Summary of MS4 Mapping
Percent of MS4 Area Mapped 10 %
No. of Major Outfalls* Mapped 22 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 Cajah’s Mountain 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
Little Gunpowder Creek (11-55-2-
(1))
C N/A
Stafford Creek (11-43- (1)) WS-IV N/A

3.4 MS4 Interconnection
The Town of Cajah’s Mountain MS4 is interconnected with another regulated MS4 and directly receives
stormwater from the City of Lenoir MS4. The number of interconnections entering the Town of Cajah’s
Mountain MS4 from the City of Lenoir is unknown due to the storm sewer not being mapped. The Town
of Cajah’s Mountain plans to map the storm sewer and flow in the future to help determine
interconnectivity (Reference BMP 19).

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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 Cajah’s Mountain MS4 jurisdictional area includes the following industrial facilities which
hold NPDES Industrial Stormwater Permits, as determined from the NCDEQ Active NPDES Stormwater
Permit List and/or Active Stormwater Permits Map.

Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number Facility Name
N/A N/A

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3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the Town of Cajah’s
Mountain as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do
not significantly impact water quality. The Town of Cajah’s Mountain has evaluated residential and
charity car washing and street washing for possible significant water quality impacts.

Street washing discharges are addressed under the Pavement Management Program in Part 10 of this
SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the
Town of Cajah’s Mountain.

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 have been evaluated by the Town of Cajah’s Mountain to determine whether they may
significantly impact water quality. The Town of Cajah’s Mountain 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
In addition to those target pollutants identified above, the Town of Cajah’s Mountain is not aware of other
significant water quality issues within the permitted MS4 area.

Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the
likely activities/sources/targeted audiences attributed to each pollutant, and identifies the associated
SWMP program(s) that address. In addition, the Town of Cajah’s Mountain 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 and been noted by code enforcement officers within the Town.
Cases of both illegal construction waste dumping and general residential or school dumping have been
noted by code enforcement officers. 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
Residents have noted a few homes have had their washing machines straight-piped out of their homes by
creating makeshift piping using water hoses exit at windows. Homes are to be connected to the
appropriate sewer system. This proves to be a source of detergents/soaps entering our storm drains in
residential neighborhoods. In addition: residential, charity, and municipal car washes allow for soaps or
waxes to enter the storm drain when vehicles are not being cleaned in the correct areas (such as vegetated
patches or in areas that do not have storm drains). This allows for toxic contaminants to enter our
waterways via the storm drain system.
Fats Oils and Grease: Health Department has noted several cases where restaurants do not empty
or own/rent grease traps for appropriate removal.

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The Health Department has reported several restaurants in Cajah’s Mountain 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 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 not properly labeled or stored
Town staff, along with some citizens have reported that containers of unknown/unmarked chemicals 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: 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. Within the Catawba River Basin roughly 46 streams are/were impacted by fecal
coliform, with 10 being listed on the 303(d) list. As this is a non-point source pollutant it is hard to locate
the exact source of this runoff, however in much of the watershed there is agricultural zoning that makes
it likely for these types of impairments to occur. Roughly 20% of land use within the basin is agricultural.
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. The 10 303(d) fecal coliform impaired streams listed can have
some attribution to septic tank leakage.
Illicit discharges: Originate from a variety of sources, with an equally varied number of effects
dependent on the chemical that is released.
Typically, illicit discharges come from businesses, residents or municipal facilities who dump chemicals
into storm drains either incidentally due to a lack of IDDE education or general carelessness. These
chemicals can vary greatly, and can include grease, oils, chemicals, cleaning solutions, paints, metals, etc.
This is a recognized problem as we have several 303(d) streams impaired from causes related to

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substances or attributions given to unclean discharges into the streams - in addition to reports generated
by the municipality. Many of the 303(d) benthos impaired streams can be attributed to IDDE issues, but
they are often from inexact/non-point sources that are attributed to illicit discharges
Illegal dumping: When residents, businesses, or municipal employees dump waste randomly in
non-permitted dumping areas.
This waste can widely vary, causing a variety of problems. For example, citizens dumping televisions on
the side of the road to avoid dumping fees, which allows for the metals or chemicals inside the tv to leach
out as stormwater passes it (mercury, lead, and other metals). It can be a case of businesses dumping
waste in watershed areas where runoff passes 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/Bonifide Farms Illicit Discharge
Public Education & Outreach
Underground Storage Tanks Business and Residents Illicit Discharge
Public Education & Outreach
Superfund Sites Development Committee Public Education & Outreach

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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 Cajah’s Mountain has contracted Western Piedmont Council of Governments (WPCOG) to
coordinate Stormwater Management Plan efforts, to ensure the Town is facilitating Best Management
Practices to protect water quality. While WPCOG will be the primary operator of the program, the Town
of Cajah’s Mountain staff (currently 1 employee – who handles all town responsibilities) will be trained
to handle internal procedures and report action/s to WPCOG. The following organizational chart is
broken down by the six elements associated with Stormwater Management. Each of the positions under
the elements will report back to the primary manager and then on to the Stormwater Program
Administrator.

Table 8: Summary of Responsible Parties
SWMP Component Responsible Position Staff Name Department
Stormwater Program
Administration
Town Administrator TBD Town of Cajah’s
Mountain
SWMP Management WPCOG Senior
Planner/Natural
Resources
Administrator
Johnny Wear WPCOG

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Public Education &
Outreach
WPCOG Senior
Planner/Natural
Resources
Administrator
Johnny Wear WPCOG
Public Involvement &
Participation
WPCOG Senior
Planner/Natural
Resources
Administrator
Johnny Wear WPCOG
Illicit Discharge
Detection &
Elimination
WPCOG Code
Enforcement Officer
Todd Justice WPCOG
Construction Site
Runoff Control
N/A N/A NCDEQ – Asheville
Regional Office
Post-Construction
Stormwater
Management
WPCOG Stormwater
Administrator
Jack Cline WPCOG
Pollution
Prevention/Good
Housekeeping for
Municipal Operations
WPCOG Senior
Planner/Natural
Resources
Administrator
Johnny Wear WPCOG
Municipal Facilities
Operation &
Maintenance Program
WPCOG Stormwater
Administrator
Jack Cline WPCOG
Spill Response Program Stormwater
Administrator and
Volunteer Emergency
Services
Jack Cline; TBD WPCOG,
Volunteer/Town Fire
Departments, if
applicable
MS4 Operation &
Maintenance Program
Town of Cajah’s
Mountain Town
Employee
TBD Town of Cajah’s
Mountain
Municipal SCM
Operation &
Maintenance Program
Town of Cajah’s
Mountain Town
Employee and
Stormwater
Administrator
TBD; Jack Cline Town of Cajah’s
Mountain and WPCOG
Pesticide, Herbicide &
Fertilizer Management
Program
Town of Cajah’s
Mountain Town
Employee and WPCOG
Stormwater
Administrator
TBD; Jack Cline Town of Cajah’s
Mountain and WPCOG

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Vehicle & Equipment
Cleaning Program
Town of Cajah’s
Mountain Town
Employee
TBD Town of Cajah’s
Mountain
Pavement Management
Program
Town of Cajah’s
Mountain Town
Employee
TBD Town of Cajah’s
Mountain
Total Maximum Daily
Load (TMDL)
Requirements
WPCOG Stormwater
Administrator
Jack Cline WPCOG

4.2 Program Funding and Budget
In accordance with the issued permit, the Town of Cajah’s Mountain 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 the Division annually. Due to the increase NPDES permit mandates, the first year of the permit cycle
will be used to determine a base line for the stormwater program funding needs. The funding mechanism
will be analyzed through the completion of a fiscal gap analysis to determine how the stormwater
program will be implemented and funding obtained

The Town of Cajah’s Mountain, has a two-year contract (which will need to be modified, adopted, and
signed every two years) with Western Piedmont Council of Governments for the following services:
Public Education and Outreach Program, Public Involvement and Participation Program, Illicit Discharge
Detection and Elimination Program, Post-Construction Site Runoff Control Program, and Pollution
Prevention and Good Housekeeping Programs. The current contract amount for the 2-year period (years 1
and 2 of the NPDES permit cycle) is $24,370.00. The Town will be responsible for the cost of the annual
NPDES permit renewal, which is to be paid to the state. Any fees charged to the development community
for BMP Inspections, Plan Review, and other associated fees will help offset cost. The Town may
determine that stormwater utility fees should be implemented; these fees would be collected by the Town
through tax or utility bills. The goal would be for the funds collected to support the stormwater program
through mapping outfalls, stream repairs, and other water quality efforts. Revenue versus funding will be
reviewed each year to determine needed changes.

Should the Town of Cajah’s Mountain choose not to renew the existing two-year contract, prior to the last
month, a revision to the existing NPDES permit and Stormwater Management Plan would need to occur.
The Town of Cajah’s Mountain would be required to renew the two-year contract, in years 2021 and
2023, to fully carry out the 5 year NPDES permit cycle. The Town of Cajah’s Mountain would be
required to fully carry out the 5 year NPDES permit cycle.

4.3 Shared Responsibility
Beginning July 2019, the Town of Cajah’s Mountain will share the responsibility, with WPCOG (referred
to as entity), to implement the following minimum control measures, which are as stringent as the
corresponding NPDES MS4 Permit requirement. The Town of Cajah’s Mountain remains responsible for
compliance if the other entity fails to perform the permit obligation and may be subject to enforcement

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action, if neither the Town of Cajah’s Mountain, nor the other entity fully performs the permit obligation.
Table 9 below summarizes individual responsibilities for each program.

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

Construction Site Runoff
Control Program
NCDEQ N/A
Post-Construction Site
Runoff Control Program
WPCOG Stormwater Partnership Y
Pollution Prevention and
Good Housekeeping
Programs
WPCOG Stormwater Partnership Y
Total Maximum Daily Load
(TMDL)
N/A N

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4.4 Co-Permittees
There are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000xxx for the Town of Cajah’s Mountain.

4.5 Measurable Goals for Program Administration
Referencing, MS4 Inspection Report for the Town of Cajah’s Mountain - 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 had not develop any procedures for doing so. In order
to meet the State requirements for this section, a self-assessment and the effectiveness of the program
components will be completed annually. Written procedures, otherwise known as, Stormwater
Management Plan: SWMP, has been drafted, but not adopted at this time. The SWMP will be adopted
during Permit Year One of the NPDES permit cycle following the acceptance of the SWMP and issuance
of the NPDES permit.

MS4 Inspection Report for the Town of Cajah’s Mountain - Program Implementation, Documentation &
Assessment, Permit Citation - III.A. Program Documentation; The City of Lenoir on the Town’s behalf
maintained some documentation regarding illicit discharge complaints and enforcement actions; however,
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 Cajah’s Mountain - Program Implementation, Documentation &
Assessment, Permit Citation - III.B. Annual Report Submittal: The latest MS4 annual report submitted
was for the 2014-2015 reporting year. The report included a brief description of the six minimum control
measures and initiative at the time. However, the report lacked detail regarding specific milestones for
the measures, overall plan accountability, or what was accomplished during the reporting period. Instead,
the report described plans for future MS4 program implementation, which largely had not yet been
implemented. Further, the 2014-2015 report did not include a fiscal analysis (Permit Citation - IV.B).

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

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 18

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

1. Annual Self-
Assessment received by
NCDEQ no later than
August 31 each year.
Permit
Ref. 1.6: Permit Renewal Application
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
2. Permit Renewal Application
Audit stormwater program
implementation for compliance
with the permit and approved
SWMP, and utilize the results to
prepare and submit a permit
renewal application package.
1. Participate in an
NPDES MS4 Permit
Compliance Audit, as
scheduled and performed
by EPA or NCDEQ.
1. TBD – Typically
Permit Year 4

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

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

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

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 19

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The Town of Cajah’s Mountain will implement a Public Education and Outreach Program 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.

The Town of Cajah’s Mountain will implement a Public Education and Outreach Program 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 Cajah’s Mountain 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
Cajah’s Mountain 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 and/or Bonifide Farms
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

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 20

The Town of Cajah’s Mountain will manage, implement and report the following public education and
outreach BMPs.

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

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

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

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

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

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Town of Cajah’s Mountain
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Page 21

Table 13: Public Education and Outreach BMPs
4. Public Event Outreach
Provide stormwater educational
information to the general public
at community events. The Town
of Cajah’s Mountain does not
hold any events, but the citizens
of the Town take part in other
nearby events to supplement this.
1. Staff will have a
booth at community
events to disperse
stormwater outreach
materials using
interactive educational
games and activities.
At minimum, one
event will be attended
per permit year.
1. Annually

Permit Years 1-5

1. Number of events
held/attended;

Number of attendees;

Number of materials
handed out.
5. Student/teacher outreach
Provide educational information
to students and teachers through
classroom, workshop, and hands-
on activities related to stormwater
BMPs.
1. Staff will provide in
class instruction and/or
stormwater
educational activities
to students that attend
Hudson Middle School
and/or Gamewell
Middle School.
1. Annually

Permit Years 1-5

1. Number of classes
and/or activities
provided;

Number of students
present at these
classes/activities.

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

Permit Years 1-5

2. Number of
workshops provided;

Number of teachers
who attended.
6. Printed Materials
Staff will design new printed
materials for target audiences to
aid stormwater education.
1. Staff will create
printed material for
local government
distribution addressing
stormwater best
practices.
1. Permit Year 1

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

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Table 13: Public Education and Outreach BMPs
2. Staff will distribute
printed materials at
events, school
presentations, and
have them on display
for public acquisition
in Government
buildings. The flyers
will also be hosted on
the WPCOG website
to enable digital access
to this resource.
2. See BMP 3

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

Permit Years 1-5

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

Permit Years 1-5

1. - 2. Number of
target pollutant
violations;

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

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 23

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

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

Permit Years 1-5

9. Evaluate Public Education and Outreach BMPs.
Evaluate the successful
components of outreach through
interest and feedback.
1. See BMP 17 1. See BMP 17

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

Permit Years 1-5

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

Date Stormwater Web
Page was added to the
Town Website.

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Town of Cajah’s Mountain
August 6th, 2020
Page 24

Table 13: Public Education and Outreach BMPs
Develop a stormwater page to be
included in the Towns existing
web site. This page will convey
the importance of water quality
and a link to the WPCOG
Stormwater webpage will be
placed on the Town’s website.
The WPCOG Stormwater
webpage will provide educational
resource links, compliant
procedures, stormwater
regulations, stormwater permit
information and good
housekeeping information.

2. WPCOG staff will
maintain and update
the WPCOG
stormwater website; by
posting the MS4
Annual Self-
Assessment, verifying
all links and contact
information are
current/active, posting
the current year fliers

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

Permit Years 1-5

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

Did links and/or
contact information
need to be updated?
Yes, No; Status;

Were new/current
fliers added to the site?
Yes, No; Status.
3. Set a hit counter in
order to monitor
engagement.
3. Annually

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

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

1. See BMP 49
2. Distribute material
(generated from BMP
3) to target audiences
(municipal employees,
schools, businesses,
and citizens).
2. See BMP 3

2. See BMP 3
3. Provide education
during enforcement
process.
3. Continuous,.

Permit Years 1-5

3. Number of citizen
interactions during
enforcement.

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Town of Cajah’s Mountain
August 6th, 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
This hotline will function 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. Establish a hotline
number for stormwater
complaints and
information.
1. Permit Year 1

1. Was hotline
established; Yes, No;

Date of establishment.

2. Identify specific
staff members who
will serve as
stormwater hotline
staff.
2. Permit Year 1

2. Was staff member
identified? 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 the
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.

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Table 13: Public Education and Outreach BMPs
5. Publicize contact
information on the
Town and WPCOG
Stormwater webpages
as well as the Town of
Cajah’s Mountain
Facebook page.
5. Continuously,

Permit Years 1-5

5. Number of hotline
calls received overall.

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 27

PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM

In reference to MS4 Permit Self Audit Report – Public Involvement and Participation, Permit Citation
II.C.2.a. Volunteer Community Involvement Program: The Town plans to grow the effort in the future.
The Town of Cajah’s Mountain 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 Cajah’s Mountain 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. BMP 12

1. BMP 12

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

1. Was the online form
established? Yes, No;
Status;

Date of establishment.

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Table 14: Public Involvement and Participation BMPs
concerns, as well as have input on
the stormwater program.
2. Use the form to
record and track
responses, inputs,
issues, and concerns
for metric reporting.

Purpose of each
question, report, or
comment will be
documented to allow
for evaluation.
2. Continuous,
following the
establishment of the
form in Permit Year 1.

Permit Years 2-5

2. Number of
questions, reports, and
comments received via
the form.
3. Maintain the web
based
complaint/reporting/in
put form on the
WPCOG website.
3. Continuously,

Permit Years 1-5

3. Were revisions to
the web form needed?
Yes, No; Status.
15. Social Media Outreach – Event Promotion
Utilize the existing Town of
Cajah’s Mountain 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 Cajah’s
Mountain Facebook
page to promote public
involvement and
participation related to
stormwater programs,
events, and projects.
The Facebook page
will also be used to
post stormwater
educational materials
and provided general
stormwater
awareness..
1. Continuously,

Permit Years 1-5

1. Total number of
posts on the Towns
Facebook page related
to the stormwater
program.
16. Water Resources Committee

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
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Table 14: Public Involvement and Participation BMPs
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.
17. Public Survey and Evaluation
Provide a mechanism for public
input by creating a survey to
engage the public and gauge
public interest in stormwater
issues and the stormwater
program. The survey will be
taking in responses/input on the
program as a whole – covering
each minimum measure and BMP
that refers to this survey.
1. Create and
administer an annual
survey to be housed on
the WPCOG
stormwater website
once a year, open to
feedback for a total of
4 weeks. The survey
will also be linked on
the Town of Cajah’s
Mountain website.

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

Permit Years 1-5

1. Number of surveys
completed.
Permit
Ref.
3.3.2: Volunteer Opportunities
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
18. Stream Cleanup

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Table 14: Public Involvement and Participation BMPs
The Town and WPCOG will
publicize an event (hosted by
WPCOG) to the public to gather
volunteers for stream cleanup
efforts to assist in public
awareness and involvement.
1. Hold stream cleanup
efforts by engaging
groups to conduct
stream cleanup
activities in
appropriate areas. The
events will be
promoted by the Town
and WPCOG.

For the Town of
Cajah’s Mountain the
stream cleanups will
focus on Gunpowder
Creek and/or water
bodies that feed into it
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;

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 NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 31

PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
MS4 Inspection Report for the Town of Cajah’s Mountain – Illicit Discharge Detection and Elimination
(IDDE), Permit Citation II.D.2.a. IDDE Program: The Town had not developed written procedures for
implementing an IDDE Program. 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 Cajah’s Mountain – Illicit
Discharge Detection and Elimination (IDDE), Permit Citation II.D.2.b. Legal Authority, the Town will
maintain and enforce the adopted stormwater ordinance and other regulatory mechanisms that provide the
legal authority to prohibit illicit connections and discharges to the MS4.
The City of Lenoir provided a map of the Town of Cajah’s Mountain outfalls and MSC locations during
the MS4 Inspection; however the map was developed in 2013, the accuracy of the map is in question and
the Town did not use the map to facilitate any MS4 activities (II.D.2.c. Storm Sewer System Map). In the
future the Town will be mapping the complete MS4 within Permit Years 1 through 5 (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 quarterly. Data such as
date screening occurred, location of inspected outfall, and photos of outfall will be recorded in GIS.
The City of Lenoir, on behalf of the Town of Cajah’s Mountain, in the past had taken a reactive approach
to Illicit Discharge investigations with no written procedures (II.D.2.e.). A list of violators were provided
to DEQ dating back to 2011; however a majority of the cases did not have a documented resolution
(II.D.2.f.). It is unclear if any of the violations were in the Town of Cajah’s Mountain. Within the new
permit cycle, the Town will be adopting an IIDE Plan to establish written procedures. A proactive stance
will be initiated with the use of a GIS application 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 educate the general public in identifying illicit discharge
and illegal dumping through the use of educational outreach materials and training opportunities.
Previously, no training had been administered (II.D.2.g. & h.). Educational material will be available to
help educate public employees, businesses, and the general public about hazards associated with illicit
discharges and the improper disposal of waste.
Public complaints of any kind could be submitted to the Town through a webpage portal or by phone;
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, will be
established on the WPCOG website. A link from the Town’s website will lead to the WPCOG portal. A
citizen can make a complaint via hotline number or through an email tool on the WPCOG webpage.
The Town of Cajah’s Mountain 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.

DRAFT NCS000xxx SWMP
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August 6th, 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. MS4 Map
1. Verify the accuracy
of existing GIS
map/data by
comparing current data
to field located major
outfalls.
1. Permit Year 1

1. Was the existing
outfall map data
verified? Yes, No;
Status.
2. Establish funding
source (such as, but
not limited to grants,
fees, and Town Funds)
for mapping the MS4
area.
2. Permit Year 2

2. Funding source was
established: Yes, No;
Status.

DRAFT NCS000xxx SWMP
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Table 15: Illicit Discharge Detection and Elimination BMPs
Develop, update, and maintain a
municipal storm sewer system
map including stormwater
conveyances, flow direction,
major outfalls, and the waters of
the United States receiving
stormwater discharges. The map
will be placed onto an arc-online
map to make it multi-use and
easily accessible for stormwater
or IDDE issues. It will be broken
into layers or separate maps
between IDDE, post
construction/stormwater issues,
and dry weather investigation (on
top of the MS4 map being the
‘base map’).
33.3% of MS4 mapping will be
completed each year (miles of
pipe, type of pipe, number of
SCMs, number of outfalls, flow
direction located, number of
conveyances mapped, were
receiving bodies located/marked).
3. Update existing map
to include open
channels and storm
drain information and
flow direction. This
data will be collected
through a mixture of
preexisting map data
(following its
validation), as well as
field work based off of
Town recommendation
and known
information.

33.3% of MS4
mapping will be
completed each year
(miles of pipe, type of
pipe, number of
SCMs, number of
outfalls, flow direction
located, number of
conveyances mapped,
were receiving bodies
located/marked).
3. Semi-annually

Permit Years 3-5

3. Was the map
updated Yes, No;
Status;

Was at least 33.3% of
the MS4 area mapped?
Yes, No; Status.
4. Add new
infrastructure to map
as new construction
occurs. Updated on an
annual basis.
4. Annually

Permit Years 1-5

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

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Table 15: Illicit Discharge Detection and Elimination BMPs
Review existing Ordinance
(Section 7 of Town of Cajah’s
Mountain Phase II stormwater
ordinance) in order to maintain
the legal authority to prohibit,
detect, and eliminate illicit
connections and discharges,
illegal dumping and spills into the
MS4, including enforcement
procedures and actions. Update
ordinance if required.

1. Review the
ordinance and update
if revision is required.
Revisions will require
council approval.
1. Annually

Permit Years 1-5

1. Were revisions to
the ordinance needed?
Yes, No; Status.
Permit
Ref.
3.4.3: IDDE Plan
Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal
dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4.
The plan shall provide standard procedures and documentation to:
a) Locate priority areas likely to have illicit discharges,
b) Conduct routine dry weather outfall inspections,
c) Identify illicit discharges and trace sources,
d) Eliminate the source(s) of an illicit discharge, and
e) Evaluate and assess the IDDE Program.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
21. IDDE Plan
Establish 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.
1. Develop written
IDDE Plan to define
the procedures of
identifying, tracking
and processing illicit
discharges, illegal
dumping and
significant contributors
of pollutants to the
MS4. Submit IDDE
Plan to DEQ for
approval.
1. Permit Year 1

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

Date draft plan is
submitted to DEQ for
approval.

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Table 15: Illicit Discharge Detection and Elimination BMPs
2. Train staff on the
processes defined in
the IDDE Plan and
what is required by the
IDDE ordinance.
2. See BMP 49

2. See BMP 49
3. Implement/Enforce
the IDDE Plan and
IDDE Ordinance.
3. See BMP 26

3. See BMP 26
22. Location of Priority Areas
Establish and maintain procedures
for locating priority areas likely to
have illicit discharges. A high
priority area is an area that has a
high chance of stormwater
pollution potential: Areas with
known dry weather outfall
flows/violations, repeat offenders,
business/commercial areas,
industrial areas, and businesses
with high pollution potential.
1. Use MS4 map to
locate outfalls near
high pollution risk
areas. As BMP 19 is
being completed,
priority areas will be
established. 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.

1. Annually,
Permit Years 1-5

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

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

Preform 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. The
inspections will consist of the
currently known outfalls and
expanded with the progress of
BMP 19.
1. Establish a
procedure to divide the
Town and create a
schedule for dry
weather inspections for
known outfalls.
1. Permit Year 1

1. Were procedures
and the schedule
established? Yes, No;
Status.
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.

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August 6th, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
24. Illicit Discharges and Trace Sources
Establish procedures to track and
document Illicit Discharge
investigations.
1. Establish procedures
to track verified
discharges and trace
sources.
1. See BMP 26

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

2. See BMP 26
25. Maintain and Implement IDDE
Plan

Maintain and implement the
IDDE Plan to detect and address
illicit discharges, illegal dumping
and any non-stormwater
discharges identified as
significant contributors of
pollutants to the MS4.
1. Monitor priority
areas likely to have
illicit discharges (BMP
22).
1. Contiiously

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.

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August 6th, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
Ref.
3.4.4: IDDE Tracking
Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was
observed, the results of the investigation, any follow-up of the investigation, the date the investigation was
closed, the issuance of enforcement actions, and the ability to identify chronic violators.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
26. IDDE Tracking
Staff will create a mechanism for
tracking and documenting the
date(s) an illicit discharge, illicit
connection or illegal dumping
was observed, the results of the
investigation, any follow-up of
the investigation, the date the
investigation was closed, the
issuance of enforcement actions,
and identifying chronic violators.
.
1. Develop the online
GIS map (BMP 19) for
tracking IDDE
violations, recording
who made the
complaint, location of
complaint, note prior
IDDE violations,
status of the
investigation and
actions taken.
1. Permit Year 1

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

Date IDDE map
developed.

2. Track illicit
discharge/connection
and illegal dumping
reports/investigations
with the online GIS
map (BMP 19) with
the IDDE layer on top
of the MS4 map.

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

Permit Years 1-5

2. Number of verified
IDDE issues.
3. Upon investigation,
enforce Illicit
Discharge/connection
and Illegal Dumping
violations to ensure the
responsible
party/violator remedies
verified illicit
discharges.
3. Continuously,

Permit Years 1-5

3. Number of
violations/enforcement
actions issued;

Number of
violations/enforcement
actions resolved.

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August 6th, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
4. Establish and
maintain a list of
chronic violators, as
applicable. Updated on
a Semi-annual basis.
4. Semi-Annually,

Permit Years 1-5

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

Permit Years 2-5

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

1. See BMP 11

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Town of Cajah’s Mountain
August 6th, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
2. Hold IDDE training
events to educate staff
and/or 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. Annually

Permit Years 1-5

2. Number of
personnel trained;

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

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

2. See BMP 12

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

1. See BMP 12

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August 6th, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
2. Train hotline staff to
differentiate between
illicit discharge
complaints and
stormwater/post-
construction
complaints. The staff
will also be trained to
keep adequate records
of the calls for metrics.
2. See BMP 12

2. See BMP 12
3. Publicize Hotline by
including the number
of educational
materials distributed.
Share the hotline
number on the Town
and WPCOG websites
and social media
accounts.
3. See BMP 12

3. See BMP 12
30. IDDE Reporting Web-based Reporting Form
Staff will establish and maintain a
web-based form where IDDE
complaints/reports can be entered
and sent to the appropriate
reporting individual. Publicize the
reporting tool in education
outreach materials as well as on
the Town of Cajah’s Mountain
website.
1. Use web based
reporting form for
IDDE reporting.
1. See BMP 14

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

1. See BMP 19

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August 6th, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
2. Evaluate response
time. Work to
minimize response
time to reported issues
and record what is
causing those issues to
be fixed in later
iterations of the plan.
Track the times
elapsed between when
an IDDE incident is
reported, and when it
is addressed.
2. Annually,

Permit Years 1-5

2. Average response
time.

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 42

PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the Town of Cajah’s Mountain 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 Cajah’s Mountain 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.
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.

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Town of Cajah’s Mountain
August 6th, 2020
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Table 17: Construction Site Runoff Control BMPs
33. Means of Public Input
Utilize the survey, the hotline, and
the online form to give citizens
methods of responding to how
construction runoff is being
managed. The survey will ask
questions regarding: how they
view construction runoff in the
Town, what they think should be
changed to improve upon said
problems, and where they believe
there should be more focus within
the program.
1. Use survey (BMP
17) to obtain feedback
about public
perspective about
construction runoff in
the Town.
1. See BMP 17

1. See BMP 17
2. Administer the
survey. The survey
will be linked to on the
WPCOG stormwater
webpage and the Town
of Cajah’s Mountain
website.
2. See BMP 17

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

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

4. See BMP 14
Permit
Ref.
3.5.5: Waste Management
Measures to require construction site operators to control waste such as discarded building materials, concrete
truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to
water quality.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
34. Waste Management
Require construction site
operators to control waste at the
construction site that may cause
adverse impact to water quality.
1. Develop an
ordinance that
addresses construction
site waste.
1. Permit Year 1

1. Ordinance
developed: Yes or No,
Status

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August 6th, 2020
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Table 17: Construction Site Runoff Control BMPs
2. Adopt developed
ordinance through
council approval.
2. Permit Year 1 2. Ordinance adopted;
Yes, No; Status;

Date of adoption
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 1-5

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

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

5. See BMP 19

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 45

PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
MS4 Inspection Report for the Town of Cajah’s Mountain – Post-construction Site Runoff Control
Program Implementation Status, Permit Citation: II.F.2.a. Legal Authority, “At the time of inspection, the
Town was utilizing a Caldwell County ordinance to implement the post-construction site runoff controls
program. The Ordinance authorized Caldwell County, rather than the Town of Cajah’s Mountain, to
review plans, request information, and enter private property to conduct inspections of post-construction
controls.” A stormwater ordinance was adopted, authorizing the Town, rather than the County to
administer the aforementioned items. Within the ordinance enabling language granting the Town of
Cajah’s Mountain the ability to require deed restrictions and protective covenants (II.F.2.e.) was included.

Contracting WPCOG, an inventory of projects will be established (BMP 35.B.1, 2, and 3) within the
municipal limits, this is in response to Permit Citation II.F.2.d. of the latest audit (2018). Along with the
inventory list proactive inspections will be administered by Staff semi-annually and certified by a private
engineer annually to ensure SCM functionality (II.F.2.g.) Upon non-compliance, enforcement action will
be taken, not a common practice in years past, but now the Town will have a GIS tracking mechanism to
proactively enforce to obtain compliance (II.F.2.i.).

MS4 Inspection Report for the Town of Cajah’s Mountain – Post-construction Site Runoff Control
Program Implementation Status, Permit Citation: II.F.3.c. Nutrient Sensitive Waters: The City of Lenoir,
on behalf of the Town of Cajah’s Mountain had not designed or constructed any SCMs in the permitted
area specifically to reduce nutrient loads. At this time it is unclear if the co-permitees with in the MS4 are
receiving discharge into the nutrient sensitive waters.

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 Cajah’s Mountain and discharge into the MS4. These elements
are designed to minimize water quality impacts utilizing a combination of structural Stormwater Control
Measures (SCMs) and/or non-structural BMPs appropriate for the community, and ensure adequate long-
term operation and maintenance of SCMs.

In accordance with 15A NCAC 02H .0153 and .1017, the Town of Cajah’s Mountain 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
WSIV Watershed Ordinance (See
map)

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August 6th, 2020
Page 46

DRAFT NCS000xxx SWMP
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Page 47

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

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 Stormwater Ordinance Section 102 11/4/19
3.6.3(a) & 15A NCAC 02H.0153(c)
Federal, State & Local Projects
Stormwater Ordinance Section 105 11/4/19

3.6.3(b) Plan Review Stormwater Ordinance Section 202 11/4/19
3.6.3(c) O&M Agreement Stormwater Ordinance Section 402 11/4/19
3.6.3(d) O&M Plan Stormwater Ordinance Section 402 11/4/19
3.6.3(e) Deed
Restrictions/Covenants
Stormwater Ordinance Section 302 and 303 11/4/19
3.6.3(f) Access Easements Stormwater Ordinance Section 408 11/4/19
Permit Requirements for
Inspections and Enforcement
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(b) Documentation Stormwater Ordinance Section 401 11/4/19
3.6.2(c) Right of Entry Stormwater Ordinance Section 402 11/4/19
3.6.4(a) Pre-CO Inspections Stormwater Ordinance Section 203 11/4/19
3.6.4(b) Compliance with Plans Stormwater Ordinance Section 203 11/4/19
3.6.4(c) Annual SCM Inspections Stormwater Ordinance Section 401 11/4/19
3.6.4(d) Low Density Inspections Stormwater Ordinance Section 302 11/4/19
3.6.4(e) Qualified Professional Stormwater Ordinance Section 401 11/4/19
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.6(a) Pet Waste Stormwater Ordinance Section 308 11/4/19
3.6.6(b) On-Site Domestic
Wastewater Treatment
Stormwater Ordinance Section 308 11/4/19

DRAFT NCS000xxx SWMP
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August 6th, 2020
Page 48

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.
A B C D

DRAFT NCS000xxx SWMP
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August 6th, 2020
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Table 20: Post Construction Site Runoff Control BMPs
BMP
No. Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
36. Qualifying Alternative Program
The QAP requirements are applicable to a portion of the Town of Cajah’s Mountain; 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. Phase II Post-construction Stormwater Ordinance
The Town has adopted and will
maintain in effect the Phase II
Stormwater Ordinance, 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
1. Train staff (field
and office) in
Stormwater Ordinance
procedures and
enforcement actions.
1. See BMP 49

1. See BMP 49

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 50

Table 20: Post Construction Site Runoff Control BMPs
selecting, designing, evaluating,
and maintaining structural and
non-structural BMPs.
2. Enforcement of the
Phase II Post-
construction
Stormwater Ordinance
to ensure compliance.
Should the correct
processes and order
not be followed, a
notice of violation will
be issued to address
the violation.
2. Continuously,

Permit Years 1-5

2. Number of notices
of violations issued;

Number of Civil
Citations issued;

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

All required submittals (as
defined by the plan review
procedures) must be received by
the reviewer before the issuance
of a Certificate of Occupancy (per
development). Should the
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.

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 51

Table 20: Post Construction Site Runoff Control BMPs
procedures not be followed, a
notice of violation and stop order
will be in accordance with the
Town’s ordinance and SOP.

The Town of Cajah’s Mountain
requests that the County withhold
the Certificate of Occupancy on
all developments that fall under
stormwater regulations within the
Town until the stormwater
requirements are met. The CO
will not be issued until all
stormwater requirements
(designs, submittals, and
inspections) are satisfied and the
Stormwater Administrator
approves the issuance.

2. Review plans for all
new development and
redevelopment sites
that will disturb greater
than or equal to one
acre. This is including
projects less than one
acre that are part of a
larger common plan of
development or sale.
This requirement also
applies to Federal, State
and Local Government
projects.
2. See BMP 35

2. See BMP 35

3. 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 BMPs to
perpetually maintain and operate
BMPs according to the O&M
plan submitted during the plan
review process and require
submission of annual inspection
reports written by a qualified
professional. Each O&M
agreement shall include an
enforcement component defining
the actions the Town can take if
the O&M plan is not followed.
1. Ensure that each
project has an approved
O&M Agreement and
O&M Plan prior to CO,
to be included in the
project checklist and
required prior to CO.
Each O&M agreement
will include a
requirement for annual
inspections.

1. Continuous

Permit Years 1-5

1. Number of
permitted projects
with O&M plans that
received their CO.

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 52

Table 20: Post Construction Site Runoff Control BMPs
40. Recordation
The plan review process shall
include verification that
permanent legal mechanisms are
in effect ensuring the project is
built consistently with its
approved plans. This will be
verified through the submittal of
an engineer’s certification and
providing an as-built. These must
be received and accepted to
approve the issuance of that
projects CO.

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

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

2. See BMP 35
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 NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 53

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 to ensure the project
has been constructed according to
the plan/design. Following
approval, annual inspections by a
qualified professional will be
completed. Low density projects
will be inspected once in a permit
term to monitor potential
unpermitted expansion and apply
enforcement if violations are
found.

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

Permit Years 1-5

1. Number of pre-CO
inspections completed;

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

Permit Year 1-5

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

Number of SCMs
under annual
inspection
enforcement.
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.
Permit
Ref.
3.6.5: Documentation
Measures to maintain adequate documentation and standardized inspection and tracking mechanisms to: (a)
Maintain an inventory of post-construction SCMs and low density projects, (b) Document, track and maintain
records of inspections and enforcement actions. Tracking shall include the ability to identify chronic violators,
and (c) Make available to developers all relevant ordinances, post-construction requirements, design standards,
checklists, and/or other materials.
A B C D

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 54

Table 20: Post Construction Site Runoff Control BMPs
BMP
No. Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
42. Documentation – Low Density
Ensure tracking and records are
maintained on low density
projects to ensure that upon
inspection, impervious overages
can be determined, and corrective
actions taken. Ensure
informational materials are
available on the WPCOG website
to guarantee accessibility outside
of office hours. Through tracking
and inspections chronic violators
will be identified. 20% of the low
density sites will be inspected per
year.
1. Maintain low
density project list to
include existing sites.
1. See BMP 35

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

2. See BMP 41
3. Provide educational
material to the general
public about low
density developments:
during the issuance of
zoning permits,
distributed through
mailings, posted on
social media, and
handed out at events.

3. Continuously

Permit Years 1-5

3. Number of low
density educational
materials distributed.
43. Documentation – High Density
Ensure tracking and records are
maintained on projects to ensure
that upon granting of final CO
and follow-up inspection
impervious overages can be
determined and corrective actions
taken. Ensure informational
materials are available online to
guarantee accessibility outside of
office hours. Through tracking
and inspections chronic violators
will be identified.
1. Maintain an
inventory of all
developments and
redevelopments
(public and private)
with SCMs. Update
inventory as projects
are reviewed,
approved, and
constructed.
1. See BMP 35

1. See BMP 35

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 55

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

Permit Years 1-5

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

Permit Years 1-5

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

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

Fecal Coliform Reduction
Protective measures have been
established through the adoption of
the pet waste component of the
Phase II Stormwater Ordinance.

1. Maintain Pet
Waste Ordinance to
reduce the amount of
pet waste.
1. Annually

Permit Years 1-5

1. Did Pet Waste
Ordinance require
revisions? Yes, No;
Status

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 56

Table 20: Post Construction Site Runoff Control BMPs
Cajah’s Mountain has a
wastewater sewer running
throughout most of the
community, but septic tanks are
still present within the more rural
parts of the town. This means that
wastewater from septic tank
problems could potentially be a
source of Fecal Coliform pollution
within the Town. An outreach
approach will be taken to assist in
reducing this pollutant and raise
awareness.

2. Develop and
supply septic tank
awareness materials
to the County
through the WPCOG
septic tank program.
These flyers will be
used to raise
awareness of septic
tank pollution and
septic maintenance.
2. Continuously,

Permit Years 1-5

2. Number of septic
tank flyers distributed.

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 57

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the
Town of Cajah’s Mountain 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 Cajah’s Mountain 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 and SCMs has not be created to date (II.G.2.b. and II.G.2.e.). 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 not being inspected annually, as required per DEQ
(II.G.2.b. c. & g.). Municipal SCMs were not inventoried to date; but “it is believed that the Town of
Cajah’s Mountain does not have municipally owned structural stormwater controls” (II.G.2.f.)
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 Cajah’s
Mountain 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 City of Lenoir 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 NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 58

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.h. 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.i addresses inconstant/lacking training for municipal employees in regards to good housekeeping
and pollution practices. This is addressed in: 46.B.5, 47.B.4, 49.B.1 BMP 53.B.5, 54.B.1, 56.B.2, 57.b.3,
61.b.1, and 45.b.1. Each of these BMPs focusing on each of the 7 programs required by the permit.

II.G.2.J 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 NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 59

Table 21: Pollution Prevention and Good Housekeeping BMPs
At the time of writing this
SWMP, the Town of Cajah’s
Mountain does not have a
municipal facility that has
potential for generating polluted
stormwater runoff. Should a
facility be developed (or
modified) that could be a potential
source of pollutants, an O&M
plan shall be developed for the
facility following this BMP.
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. Permit Year 1

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

4. See BMP 46

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 60

Table 21: Pollution Prevention and Good Housekeeping BMPs
46. Municipal Facilities
The municipal facilities operation
and maintenance program 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 and shall be
enforced through performing
routine inspections. If a facility is
subject to SPCC requirements,
then specific inspection
procedures will be completed per
the SPCC requirements.

At the time of writing this
SWMP, no municipal facilities
within the Town would fall under
SPCC requirements. Should one
be developed or re-evaluated, it
will be managed as such.
1. Verify the existing
list of facilities is
correct by using tax
records and Town
data. Field visits may
be needed if data is not
clear. Make note of
SPCC facilities.
1. Permit Year 1

1. Is the facility list
verification complete:
Yes or No, Status;

Date of completion.

2. Use tax data and
facility visits to
determine if the
facility has a potential
pollutant and/or spill
risk (following SPCC
requirements).
2. Permit Year 1

2. Number of facilities
with potential
pollutants/spill risk;

Number of potential
SPCC facilities.
3. Perform facility
inspections to ensure
the Town is following
good housekeeping
measures.
3. Annually

Permit Years 1-5

3. Number of facilities
inspected,

Number of SPCC
permitted facilities
inspected.
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).

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 61

Table 21: Pollution Prevention and Good Housekeeping BMPs
5. Train municipal
facility staff on proper
stormwater awareness
and good
housekeeping
methods.

5. See BMP 49

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

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 NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 62

Table 21: Pollution Prevention and Good Housekeeping BMPs
Spill response program for
facilities and operations that store
and/or use materials that pose a
spill risk. The program will be
designed in a way that tracks
potential polluting facilities as
well as defining the
procedures/materials required for
spill response in those facilities.
The definition of reportable spills
will be written into each facility
spill response plans following
§143-215.85.
At the time of developing this
SWMP, the Town of Cajahs
Mountain does not have a
municipal facility that would store
potential pollutants or be a spill
risk. Should one be revaluated as
such, or developed, these
procedures will be followed.

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

DRAFT NCS000xxx SWMP
Town of Cajah’s Mountain
August 6th, 2020
Page 63

Table 21: Pollution Prevention and Good Housekeeping BMPs
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.
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 O M Plan.
3. Permit Years 2-5

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

Permit Year 2-5

4. Number of MS4
inspections completed.

49. MS4 O&M Training

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

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

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

Permit Years 1-5

1. Number of trainings
held;

Number of personnel
trained.

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

1. Continuously

Permit Years 1-5

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

1. See BMP 50

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Table 21: Pollution Prevention and Good Housekeeping BMPs
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.
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 Cajah’s Mountain
need to install one following
expansion, these procedures will
be followed..
1. Maintain an
inventory of
existing Town-owned
SCMs with
information
including type, year
built, date of last
inspection, and
maintenance actions.
1. See BMP 35

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

2. Were any
municipal SCM
O&M’s developed?
Yes, No; Status.
3. Review/Update
SCM inventory as
necessitated
by new Town
development.
3. See BMP 53

3. See BMP 53
53. Municipal SCMs

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Table 21: Pollution Prevention and Good Housekeeping BMPs
The municipal SCM/s operation
and maintenance program will
ensure the stormwater structures
are being managed/maintained in
a way that does not negatively
impact water quality. The SCMs
will be maintained in a scheduled
and well-defined manner written
in its O&M plan.

However, at the time of
developing this SWMP the Town
of Cajah’s Mountain does not
currently have a municipally
owned SCM. Should the Town
need to install one following
expansion, these procedures will
be followed.
1. Verify the existing
list of municipal SCMs
is correct by visiting
the sites to determine
type and condition.
Use aerial photography
in conjunction with
Town records to
determine SCM
location/ ownership.
1. Permit Year 1

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

Permit Years 1-5

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

Permit Years 1-5

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

Permit Years 1-5

4. Number of issues
identified/recorded;

Number of corrective
actions/repairs taken.

5. Should a municipal
SCM be installed,
training on the
maintenance of the
SCM and its function
shall be held.

5. See BMP 49 5. See BMP 49

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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.
1. Provide training to
staff on the use,
storage, and handling
to get officially
certified. The training
will include methods
of using minimal
chemicals to reduce
harmful effects,
especially around
SCM maintenance.

1. See BMP 49

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

Permit Years 1-5

1. Number of certified
municipal
personnel/contractors.

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

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Table 21: Pollution Prevention and Good Housekeeping BMPs
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.

At the time of writing this
SWMP, the Town of Cajah’s
Mountain does not own or
maintain any municipal vehicles.
Should one be purchased, these
cleaning procedures will be
followed.
1. Establish Standard
Operating Procedure
for containing and
disposing of vehicle
and equipment wash
water. The procedures
will be defined
through the facilities
O&M plan.
1. See BMP 45

1. See BMP 45
2. Provide routine
vehicle pollution
prevention training to
staff.
2. See BMP 49

2. See BMP 49
3. Wash all municipal
light vehicles, Town
emergency vehicles,
and equipment using
an established method
listed under this BMP,
or utilize a commercial
carwash facility that
contains and treats
wash water where
applicable.
3. Continuously

Permit Years 1-5

3. Number of vehicle
washings performed;

Was vehicle washing
completed per this
BMP? Yes, No; Status;

Provide quarterly
invoices from
commercial carwash if
utilized.
4. Record washing
procedures. Upon
facility inspection
(BMP 46) verify that
documentation is being
kept ensuring
compliance and said
documentation shows
the facility is
following the best
management practices
defined in their O&M
plan.
4. See BMP 46 4. See BMP 46
57. Vehicle and Equipment Maintenance
Measures to ensure that the waste
generated by vehicle maintained
at municipal facilities (included,
but not limited to, oils, any
running fluids, batteries, belts and
1. Ensure the Town
has obtained a NPDES
industrial permit for all
subject municipal
facilities/operations.
1. Permit Years 1

1. Log of industrial
permit/s and status.

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August 6th, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
other non-fluid vehicle waste) is
being disposed of properly.

At the time of writing this
SWMP, the Town of Cajah’s
Mountain does not own any
municipal vehicles, maintain
municipal vehicles, or have a
facility in which pollution could
be a risk. Should a vehicle be
purchased, or a facility built, this
BMP will be followed to
minimize vehicle pollutant risk.

2. Perform waste
inspections during
facility inspections
(See BMP 46).
2. See BMP 46

2. See BMP 46.
3. Provide routine
pollution prevention
and waste management
training to staff.
3. See BMP 49

3. See BMP 49
Permit
Ref.
3.7.7: Pavement Management Program
Measures to reduce pollutants in stormwater runoff from municipally-owned streets, roads, and parking lots
within the permittee’s corporate limits. The permittee shall implement measures to control litter, leaves, debris,
particulate and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and
documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
58. Street and Parking Lot Sweeping
Measures to reduce pollutants in
stormwater runoff from
municipally owned streets, roads,
and parking lots within the
permittee’s corporate limits. The
Town of Cajah’s does not have a
regular street cleaning service due
to only having one municipal
road. To supplement this, an
outreach approach will be taken to
reduce pollutant buildup from
Town residents/businesses. Non-
municipal right of way
conveyances/inlets with frequent
issues will be tracked to assist in
prioritizing their maintenance.

The Town of Cajah’s Mountain
only has one municipally owned
1. The municipal road
and parking lots will
be swept annually to
minimize pollutant
build up. Litter/debris
pickup is done
continuously.
1. Annually

Permit Years 1-5

1. Total number of
lane miles swept;

Were the municipal
parking lots cleaned?
Yes, No; Status.
2. Track
conveyances/infrastruc
ture within the
municipal boundaries
that have frequent
problems with
pollution to prioritize
their maintenance.
2. See BMP 50 2. See BMP 50

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Table 21: Pollution Prevention and Good Housekeeping BMPs
street and 2 parking lots which
will be swept annually. The road
and parking lots are kept free of
litter year round.

As part of the MS4 O&M Plan
(BMP 48), the Town will inspect
right-of-way
conveyances/infrastructure and
will report findings to the
County/DOT to reduce the
pollutant load generated by non-
municipal roads.

3. Inspect and report
the condition of right-
of-way conveyances
and infrastructure (as
part of the MS4 O&M
Plan BMP 48 & 51) to
reduce pollutant load
from non-municipal
roads.
3. See BMP 50 3. See BMP 50
4. Develop and
distribute educational
flyers regarding street
runoff pollution to
help supplement street
cleanings by reducing
pollutant load
generated by the
Towns
residents/businesses.
4. Continuously

Permit Years 1-5
4. 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. Public waste
receptacles located on
municipally owned
parcels and within
Town limits are
serviced on an as
needed basis.
1. Continuously

Permit Years 1-5

1. Number of full time
employees and/or
contractors
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 Collection

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August 6th, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
Implement measures to control
leaves and debris within the
municipal Town limits (to include
all properties). The Town of
Cajahs Mountain does not have a
leaf pick up service, to
supplement this an educational
approach will be taken alongside
including leaf management
procedures in the MS4 O&M plan
(BMP 48).

Should issues arise from this
approach, further
measures/revisions to the MS4
O&M plan shall be made to
address said issues.
1. Leaves are disposed
of by individual
property owners.
Leaves collected on
town property will be
bagged and properly
disposed of.
1. Annually

Permit Years 1-5

1. Number of bags
Town disposed of.
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.

The Town of Cajah’s mountain
relies on Caldwell County for its
emergency services. As such,
trainings will be held for first
responders.
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.